reply to attention of · res rad rso slua sml sop ta tede u-234 u-235 u-238 ufp-qapp uxo wwii ......

REPLY TO

ATTENTION OF

DEPARTMENT OF THE ARMY US ARIYIY INSTALLATION MANAGEMENT COMMAND

2405 GUN SHED ROAD JOINT BASE SAN ANTONIO FORT SAM HOUSTON, TX 78234-1223

June 1, 2017

ATTN: Document Control Desk Deputy Director, Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Mailstop TB F5 US Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Deputy Director:

We are requesting an amendment to US Nuclear Regulatory Commission License Number SUC-1593 (docket number 040-9083) to replace three annexes to the Environmental Radiation Monitoring Plan. The licenses includes by reference the following three documents:

• "Site-Specific Environmental Radiation Monitoring Plan Fort Polk Louisiana Annex 11," dated September 2016

• "Site-Specific Environmental Radiation Monitoring Plan Fort Riley, Kansas Annex 12," dated September 2016

• "Site-Specific Environmental Radiation Monitoring Plan Pohakuloa Training Area, Hawaii Annex 17," dated September 2016

Figure 1-2 in each of the above annexes is incorrect. Apparently, when these figure~ were resized during editing, locations shown in the figures were not scaled properly to match the resizing. I enclose the corrected versions (only figure 1-2 in each annex is changed) of these annexes to replace the above three annexes as follows:

• "Site-Specific Environmental Radiation Monitoring Plan Fort Polk Louisiana Annex 11," dated May 2017

• "Site-Specific Environmental Radiation Monitoring Plan Fort Riley, Kansas Annex 12," dated May 2017

• "Site-Specific Environmental Radiation Monitoring Plan Pohakuloa Training Area, Hawaii Annex 17," dated April 2017 '

In addition, for the purpose of efficiency, we are requesting an amendment to the license that will allow us to make minor changes to any annex when we discover minor errors similar to the above. The amendment should allow us to make such changes and require us to inform you of such changes without requiring us to submit a request to amend the license (as we are doing with this letter).

-2-

Thank you for your consideration. If you have any questions concerning this letter, please contact me by telephone at (210) 466-0368 or by email at [email protected].

Enclosures

Sincerely,

CHERRY ROBE., Digitallysignedby • ! CHERRY.ROBERT.NJR. 1097626231

: . ON: c=US, o=U.S. Government,

RT.N.JR.10976' 'ou=DoD,ou=PKl,ou=USA, ;· ..• ,cn=Ef:!ERRY.ROBERT.NJR. 1097626

26231 />;· .. ~~!e:2017.06.0l 15:35:57-05'00'

Robert N. Cherry License Radiation Safety Officer

REVISED FINAL

SITE-SPECIFIC ENVIRONMENTAL RADIATION MONITORING PLAN FORT POLK, LOUISIANA ANNEXll

FOR MATERIALS LICENSE SUC-1593, DOCKET NO. 040-09083

May 2017

Submitted By:

U.S. ARMY INSTALLATION MANAGEMENT COMMAND ATTN: IMSO, Building 2261 2405 Gun Shed Road, Fort Sam Houston, Texas 78234-1223

Submitted To:

U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards 11545 Rockville Pike, Two White Flint North, Rockville, Maryland 20852-2738

THIS PAGE WAS INTENTIONALLY LEFT BLANK

TABLE OF CONTENTS

Page

ACRONYMS AND ABBREVIATIONS .................................................................................................. iv

1.0 INTRODUCTION ......................................................................................... ; ................................ 1-1

I.I PURPOSE .............................................................................................................................. 1-1 1.2 INSTALLATION BACKGROUND ...................................................................................... 1-1 1.3 HISTORICAL INFORMATION .............................................................. : ............................. 1-3 1.4 PHYSICAL ENVIRONMENT .............................................................................................. 1-3 1.5 EVALUATION OF POTENTIAL SOURCE-RECEPTOR INTERACTIONS ..................... 1-7

2.0 ERMP SAMPLE DESIGN .......... ~ .................................................................................................. 2-1

2.1 SURFACE WATER AND SEDIMENT ................................................................................ 2-1 2.2 GROUNDWATER ................................................................................................................. 2-2 2.3 SOIL ....................................................................................................................................... 2-2

3.0 ERMP METHODOLOGY ............................................................................................................ 3-1

3.1 SURFACE WATER SAMPLING ......................................................................................... 3-1 3 .2 SEDIMENT SAMPLING ...................................................................................................... 3-1

4.0 RESRAD CALCULATIONS ........................................................................................................ 4-1

4.1 RESRAD INPUTS ................................................................................................................. 4-2 4.2 RESULTS ............................................................................................................................... 4-3

5.0 REFERENCES ............................................................................................................................... 5-1

LIST OF TABLES

Table 1-1. Recommended ERM Sample Location .................................................................................... 1-1

Table 2-1. U-238/U-234 Activity Ratios for Surface Water and Sediment Samples in 2013 .................. 2-2

Table 4-1. Specific Activity and Mass Abundance Values ........................................................................ 4-1

Table 4-2. Non-Default RESRAD/RESRAD-OFFSITE Input Parameters for Fort Polk RCA ................ 4-2

Table 4-3. Non-Default RESRAD-OFFSITE Input Parameters for Fort Polk RCA ................................ .4-3

Table 4-4. RESRAD-Calculated Maximum Annual Doses for Resident Farmer Scenario ...................... .4-3

LIST OF FIGURES

Figure 1-1. Installation and Radiation Control Area Location Map ......................................................... 1-2

Figure 1-2. Radiation Control Area (Ranges 33 and 34A) and Proposed ERM Samples ......................... 1-5

Figure 4-1. Residential Farmer Receptor Dose Graphs ............................................................................. 4-4

Revised Final Site-Specific ERMP Fort Polk, Louisiana

iii May2017

ASR bgs CD CFR CG CoC DGPS DoD DOE DU ELAP ERM ERMP HASL ICP-MS IMC OM IUA kg LUA mz

mrem/y mSv/y NRC ORAP PAERMP

QA QC RCA RES RAD RSO SLUA SML SOP TA TEDE U-234 U-235 U-238 UFP-QAPP uxo WWII

ACRONYMS AND ABBREVIATIONS

Archives Search Report Below Ground Surface Compact Disk Code of Federal Regulations Commanding General Chain-of-Custody Differential Global Positioning System U.S. Department of Defense U.S. Department of Energy Depleted Uranium Environmental Laboratory Accreditation Program Environmental Radiation Monitoring Environmental Radiation Monitoring Plan\ Health and Safety Laboratory Inductively Coupled Plasma-Mass Spectroscopy Installation Management Command Intensive Use Area Kilogram Limited Use Area Square Meters Millirem per Year MilliSievert per Year U.S. Nuclear Regulatory Commission Operational Range Assessment Program Programmatic Approach for Preparation of Site-Specific Environmental Radiation Monitoring Plans Quality Ass.urance Quality Control Radiation Control Area Residual Radiation Radiation Safety Officer Special Limited Use Area Source Material License Standard Operating Procedure Training Area Total Effective Dose Equivalent Uranium-234 Uranium-235 Uranium-238 Uniform Federal Policy for Quality Assurance Project Plan Unexploded Ordnance World War II


· iv May 2017

1.0 INTRODUCTION

This Site~Specific Environmental Radiation Monitoring Plan (ERMP) has been developed to fulfill the U.S. Army's compliance with license conditions #18 and #19 of the U.S. Nuclear Regulatory Commission (NRC) source material license (SML) SUC-1593 for the possession of depleted uranium (DU) spotting rounds and fragments as a result of previous use at sites located at U.S. Army installations. This Site-Specific ERMP is an annex to the Programmatic Approach for Preparation of Site-Specific ERMPs (PAERMP) (ML16004A369) (U.S. Army 2015) and describes the additional details related to Fart Polk, Louisiana, in addition to those presented in the P AERMP.

1.1 PURPOSE

NRC issued SML SUC-1593 to the Commanding General (CG) of the U.S. Army Installation Management Command (IMCOM) authorizing the U.S. Army to possess DU related to historical training with the 1960s-era Davy Crockett weapons system at several installations nationwide. In order to comply with the conditions of the license, this Site-Specific ERMP has been developed to identify potential routes for DU transport and describe the monitoring approach to detect any off-installation migration of DU remaining from the use of the Davy Crockett weapons system at Fort Polk, Louisiana. The Installation will retain the final version of this Site-Specific ERMP. In accordance with license condition #19, the U.S. Army is required to implement fully this Site-Specific ERMP within 6 months of NRC approval. This Site-Specific ERMP and its implementation is then subject to NRC inspection. Table 1-1 summanzes the locations, media, and frequency of sampling described further in this Site-Specific ERMP.

Table 1-1. Recommended ERM Sample Location

Sample Location [ Sample Media [ Sample Frequency

Co-located surface water and sediment samples downstream

(SWS-04) from the Range 33 and Range 34A RCAs, as shown in

Figure 1-2 based on the rationale presented in Section 2.1

Surface water and sediment based on the programmatic rationale presented in the P AERMP and site-specific details presented in

Section 2

1.2 INSTALLATION BACKGROUND

Quarterly unless prevented by weather (e.g., regional flooding)

Fort Polk is located in western Louisiana, approximately 3 miles southeast of the town of Leesville and approximately 35 miles southwest of the city of Alexandria in Vernon Parish, Louisiana (Figure 1-1 ). The installation was established in 1941 as Camp Polk and provided training for soldiers during World War II (WWII). After WW II, the installation went through a series of deactivations and reactivations revolving around international crises. Camp Polk was renamed Fort Polk in November 1955 and was activated as a permanent installation in 1961. Iil 1993, Fort Polk became the home of the Joint Readiness Training Center, which remains the primary tenant today.

The operational range footprint at Fort Polk includes a total of 156 ranges encompassing 150,121 acres. Ownership of the main post, as indicated by the installation boundary, is divided into two portions. In general, the northern portion of the main post is owned by the U.S. Army while the southern portion, referred to as the Intensive Use Area (IUA), is owned by the U.S. Forest Service. In addition, operational ranges are included within the Limited Use Area (LUA) and the Special Limited Use Area [SLUA], which are owned by the U.S. Forest Service (EA 2013).


1-1 May2017

f --·----.. r---- . ----·--· ) -·--

; .----1 L,

J I ! I) I

I.!-

Ft Polk

- ·-,

Legend

i.:J Fort Polk Installation Boundary

c::::J Radiation Control Area

D Dudded Impact Area

*" 1ns11111.11C Location

.....

NA110NWIDE DU PROGRAM (DAVY CROCKETT)

U.S.A

INSTALLATION & RADIATION CONTROL AREA LOCATION MAP

FORT POLK LEESVILLE, LA

DATE FIGURE

!11812016 1-1

Figure 1-1. Installation and Radiation Control Area Location Map

Revised Fi na l Site-Specifi c ERMP Fo11 Po lk, Loui siana

1-2 May 201 7

An Archives Search Report (ASR) (USACE 2008) confirmed the presence of two ranges where the Davy Crockett weapons systems were used at Fort Polk. Ranges 33 and 34A or the radiation control areas (RCAs) consist of 247 and 242 acres, respectively (Figure 1-2).

· 1.3 HISTORICAL INFORMATION

The MlOl spotting round contains DU, which was a component of the 1960s-era Davy Crockett weapons. system. Used for targeting accuracy, the MlOl spotting rounds emitted white smoke upon impact. The rounds remained intact or mostly intact on or near the surface following impact and did not explode. Remnants of the tail assemblies potentially may remain at each installation where the U.S. Army trained with the Davy Crockett weapons system from 1960 to 1968. These installations include Fort Benning, Fort Bragg, Fort Campbell, Fort ,Carson, Fort Gordon, Fort Hood, Fort Hunter Liggett, Fort Jackson, Fort Knox, Fort Polk, Fort Riley, Fort Sill, Fort Wainwright (includes Donnelly Training Area [TA]), Joint Base Lewis-McChord (Fort Lewis and Yakima TA), Joint Base McGuire-Dix-Lakehurst (Frankford Arsenal Range), Schofield Barracks Military Reservation, and Pohakuloa TA.

The U.S. Army cioes not know if any cleanup or retrieval of these rounds or remnants has occurred at Ranges 33 and 34A; therefore, the U.S. Army assumes that most, if not all, of the 370 kilograms (kg) of DU from the rounds fired remains in the RCA.

1.4 PHYSICAL ENVIRONMENT

Fort Polk is located on the West Gulf Coastal Plain section of the Coastal Plain Physiographic Province. The terrain is characterized by flat to gently rolling plains in the southern portion of the installation and gently rolling to rolling plains across the remainder of the installation.

The operational range area on Fort Polk is drained by seven sub-watersheds: Anacoco Bayou, Calcasieu River, Bundick Creek, Whiskey Chitto Creek, Sixmile Creek, Tenmile Creek, and Kisatchie Bayou. The installation is located on a topographic high where nearly all streams originate on-range and flow off-installation in a radial pattern. Streams generally flow in a southerly direction and eventually empty into the Gulf of Mexico.

The Dudded Impact Area is drained to the south-southeast by West Fork Sixmile Creek and East Fork Sixmile Creek within the Sixmile Creek sub-watershed. However, only West Fork Sixmile Creek drains areas of the Dudded Impact Area associated with historical DU usage (i.e., Ranges 33 and 34A) (Figure 1-2).

Fort Polk is underlain by three aquifers (alluvial, Chicot, and Evangeline) that are further underlain by the Castor Creek confining unit. The Chicot and Evangeline aquifers serve as a primary source of drinking water in the vicinity of the installation and the Chicot aquifer.is designated as a solesource aquifer. The depth to water in the surficial unconfined aquifers ranges from 10 to 30 feet below ground surface (bgs). Locally, groundwater flow is generally to the southeast and reflects the dip direction of the geologic units, which varies from 50 to 70 feet per mile near the outcrop and· may discharge to local surface water off-range. Depth to water increases significantly down-dip. Groundwater within the Chicot aquifer is generally encountered at 30 to 40 feet bgs in supply wells located on the Cantonment Area.


1-3 May 2017

93""6"W ~~~~~~~~~~~, LAgond

Revised Fi nal Site-Specifi c ERMP Fort Polk, Louisiana

(-1 Fort Pdk lnst.ll alion Boundory

CJ Rodlatlon Cootrol Alea

O Oudded tmpa:tAlea

;:::: Watershed Boundary

+ Surface Weter Aow Direction

e OAAP Groundwater Wells

SUrfac• Water & Soclment Sampl ing LocatJons ... ==.:~;~~· ... ~==.:~;~~I:• Not

Figure 1-2. Radia tion Cont rol Area (Ra nges 33 a nd 34A) a nd Proposed ERM Sa mples

1-5

HA110HwtDE DU PROGRAM (DAVY CROCKETI)

U S.A RADIATION CONTROL AREA (RANGES 33 & 34A)

& PROPOSED ERM SAMPLES FORT POLK

LEESVILLE, LA

DATI!

51112017

ACUAE

1-2

May 201 7

1.5 EVALUATION OF POTENTIAL SOURCE-RECEPTOR INTERACTIONS

The transport of DU can be potentially completed along the identified pathways to human and/or ecological receptors. Specific details regarding the potential receptors for the Range 33 and 34A RCAs at Fort Polk are as follows:

• Surface Water Use-No known use of surface water exists for consumption of drinking water downstream from Fort Polk.

• Recreational Use-Potential interaction with surface water and sediment is possible via recreational activities such as fishing and swimming within 15 miles downstream from the installation. During the Operational Range Assessment Program (ORAP) Phase II assessment, calculation of uranium activity ratios in surface water and sediment concluded that the detected isotopes originated from naturally occurring sources and are not attributable to DU containing munitions used at the installation (EA 2013).

• Sensitive Environments-Sensitive environments downstream from Fort Polk include riparian and wetland areas, the Kisatchie National Forest, and scenic rivers.

• Habitat-The presence of wetland areas, the Kisatchie National Forest, and scenic rivers provides the potential habitat for federally and state-listed species with a full aquatic developmental life-cycle (e.g., Kisatchie stream crayfish, southern creek mussel, and Louisiana pigtoe ).

• Ecological Receptors-The Dudded Impact Area (including the Range 33 and 34A RCAs) are drained by the West Fork Sixmile Creek, which includes off-range sensitive environments (Sixmile Creek, Kisatchie National Forest, and wetland areas) and ecological receptors, such as the Kisatchie stream crayfish, southern creek mussel, and Louisiana pigtoe.

• Groundwater Use-Groundwater is used for public and private drinking water supply within 4 miles downgradient from the installation boundary. There are numerous wells downgradient from the installation's southern boundary that access water from the Chicot and Evangeline aquifers. However, the Dudded Impact Area including the RCAs does not have any downgradient well receptors within 4 miles (EA 2013).

In summary, potential human receptors include those within the Fort Polk area and Vernon Parish relying on potential public and private water wells outside the 4-mile distance downgradient from the RCAs. Ecological receptors include sensitive environments, such as Sixmile Creek, Kisatchie National Forest, and wetland areas.


1-7 May2017

2.0 ERMP SAMPLE DESIGN

The PAERMP documented the conditions (i.e., "if-then" statements) for the sampling of each environmental medium to be used during the development of the Site-Specific ERMPs, and only

· environmental media recommended for sampling in the PAERMP are presented iri the sections below. Per the PAERMP, no sampling will occur within the RCAs or in unexploded ordnance (UXO) areas (also referred to as Dudded Impact Areas). In addition, background/reference sampling is not required because the determination of DU presence will be based on an examination of the isotopic uranium ratios. The sampling approach and rationale for each medium for the RCAs (Ranges 33 and 34A) at Fort Polk are discussed in the following sections.

2.1 SURFACE WATER AND SEDIMENT

The surface water and sediment sampling approach will involve the quarterly collection of one collocated sample from a location downstream from the RCAs at Fort Polk (Figure 1-2) where surface water flows throughout the year. If surface water is not flowing when a quarterly sampling event is planned (e.g., dry stream) or when sampling is too dangerous (e.g., rapid flow during flooding), no surface water samples will be collected during that event. Sediment samples will be collected on a quarterly basis unless sediment is inaccessible when a quarterly sampling event is planned (e.g., flooding).

The· surface water and sediment sampling location was selected based on the surface water hydrology and potential for DU contribution and is located as follows:

• SWS-04-The selected perennial sampling point is located on the West Fork Sixmile Creek, downstream from Ranges 33 and 34A at the installation's southern boundary. This sample

. location allows for relatively easy access, and site conditions are similar to previous surface water sampling locations at Fort Polk.. The stream channel at the SWS-04 location is approximately 20 feet wide.

Additional locations were sampled during the ORAP Phase II assessment (Figure 1-2). These locations were not selected for evaluation of the Fort Polk RCAs based on the surface water hydrology and potential for DU contribution, and are located as follows:

• SWS-03 and SWS-05-While these locations are also generally downgradient from the RCAs, neither location is part of the sub-watershed that captures surface water flow from the RCAs and discharges into the West Fork Sixmile Creek. SWS-03 is located on Birds Creek, which is part of the Whiskey Chitto Creek watershed, and SWS-05 is located on the East Fork Sixmile Creek sub-watershed.

• SWS-09-This location is farther south of SWS-04 and was used as a reference sample location during the ORAP Phase II assessment as it is not influenced by runoff from the RCAs. Furthermore, as discussed above, background/reference sampling is not required under this Site-Specific ERMP.

Surface water and sediment samples will be analyzed for total/isotopic uranium using U.S. Department of Energy (DOE) Health and Safety Laboratory (HASL) method 300 (alpha spectrometry). Further details on analytical procedures and quality assurance/quality control (QA/QC) information are presented in Annex 19. When analytical sampling results from locations outside the RCA indicate that the uranium-238/uranium-234 (U-238/U-234) activity ratio exceeds 3.0, the U.S. Army will notify NRC within 30 days and collect additional surface water and sediment samples within 30 days of the


2-1 May2017

notification to NRC, unless prohibited by the absence. of the sampling media. The analytical samples displaying an activity ratio exceeding 3.0 will be reanalyzed using inductively coupled plasma-mass spectroscopy (ICP-MS) for their U-234, uranium-235 (U-235), and U-238 content to calculate the U-235 weight percentage specified in 10 Code of Federal Regulations (CFR) § 110.2 (Definitions) and then to determine if the sample results are indicative of totally natural uranium (at or about 0.711 weight percent U-235) or DU mixed with natural uranium (obviously less than 0.711 weight percent U-235).

Surface water and sediment samples will be attempted to be collected quarterly. In the event that the sampling location is dry when the field crew mobilizes to collect the samples, only a sediment sample will be collected at that location. If surface water routinely flows from the RCA, sampling of the surface water will occur every 3 months. If flow is intermittent, then sampling will occur during that flow, but no less than 3 months apart.

The recommended downstream sampling location, SWS-04, for the environmental radiation monitoring (ERM) and the reference location, SWS-09, were sampled during the ORAP Phase II assessment in 2013 and analyzed for uranium for both surface water and sediment (EA 2013). The U-238/U-234 activity ratios from the wet and dry season sampling events in 2012/2013 is presented in Table 2-1.

Table 2-1. U-238/U-234 Activity Ratios for Surface Water and Sediment Samples in 2013

Downstream (SWS-04) 3 0.64-0.92

Reference (SWS-09) 3 0.76-1.77 • The U-238 to U-234 activity ratio and the weight percent U-235 are used to determine whether a given sample is indicative of natural, depleted, or enriched uranium. U-238/U-234 activity ratios of 3.0 or less are representative of natural uranium, whereas higher ratios are potentially indicative of DU (NRC 2016).

2.2 GROUNDWATER

Groundwater samples collected during the ORAP Phase II quantitative assessment in 2013 were not analyzed for radiological parameters (EA 2013). Presently, no groundwater monitoring wells are located at or near the RCAs. Since surface water is known to recharge groundwater, any DU potentially present in surface water that could impact groundwater will likely be detected through surface water and sediment sampling. For these reasons and the additional rationale included in the PAERMP (U.S. Army 2015), groundwater sampling is not planned for Fort Polk.

2.3 SOIL

If an area of soil greater than 25 square meters (m2) eroded from an RCA is discovered during

routine operations and maintenance activities, the U.S. Army will sample that deposit semiannually with one sample taken per 25 m2 unless the soil erosion is located in a UXO area. The collection of ERM samples in UXO areas generally will not occur. Exceptions will occur only with documented consultation among the License Radiation Safety Officer (RSO), installation safety personnel, and range control personnel, who will advise the Installation Commander (i.e., they will prepare a formal risk assessment in accordance with U.S. Army [2014]). The Installation Commander will then decide whether to allow the


2-2 May 2017

collection. Otherwise, Fort Polk does not meet any other criteria that would require soil sampling in accordance with the PAERMP (U.S. Army 2015).

Prior to mobilization, field sampling personnel will contact Range Control, the Installation RSO, or designee to determine if erosional areas within the RCA have been identified and, if so, sampled in accordance with requirements in Section 3.0 and Annex 19.


2-3 May 2017

3.0 ERMP METHODOLOGY

The sampling and laboratory analysis procedures to be utilized during the ERM are described below. These procedures provide additional details and required elements to support the Site-Specific ERMP and must be utilized in conjunction with the standard operating procedure (SOPs) during execution of ERM activities. This Site-Specific ERMP is to be used in conjunction with Annex 19, which addresses programmatic requirements associated with ERM sampling, such as chain-of-custody (CoC), packaging for shipment, shipping, collecting field QC samples (e.g., field duplicate samples), and documenting potential variances from sampling procedures. Annex 19 has been prepared in accordance with guidance from the Uniform Federal Policy for Quality Assurance Project Plan (UFP-QAPP) Optimized Worksheets (IDQTF 2012). All entry to Fort Polk will be coordinated with the Fort Polk Installation Safety Office and Range Control prior to mobilizing for fieldwork.

Only a laboratory that the U.S. Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) has accredited for uranium analysis using both alpha spectrometry and ICP-MS methods will perform radiochemical analyses for the purposes ofNRC license compliance. The U-238 to U-234 activity ratio and the weight percent U-235 are used to determine whether a given sample is indicative of natural uranium or DU. The laboratory will use alpha spectrometry to analyze samples for U-234 and U-238 activities in order to comply with license condition #17 in NRC SML SUC-1593. All samples with U-238/U-234 activity ratios exceeding 3.0 will be reanalyzed using ICP-MS for their U-234, U-235, and U-238 content to identify samples with DU content (NRC 2016). The ICP-MS results for U-234, U-235, and U-238 are summed to calculate a total mass of uranium present, which will be used to calculate the weight percentage of U-235 and then to determine if the sample results are indicative of . totally natural uranium (at or about 0.711 weight percent U-235) or DU mixed with natural uranium (obviously less than 0.711 weight percent U-235). Additional details about the sampling and analysis to support this Site-Specific ERMP are included in Annex 19.

3.1 SURFACE WATER SAMPLING

A surface water sample will be collected at SWS-04 and submitted for laboratory analysis. The grab surface water sample will be collected using disposable equipment (e.g., tubing) or collected directly into sample containers. Details of the surface water sampling and the associated field procedures are provided in Annex 19.

Sampling activities, including documentation of the site conditions and the sample details, will be included within the field logbook. Following the sampling, each location will be surveyed with a differential global positioning system (DGPS) unit to identify the location with sub-meter accuracy and documented in the field logbook. Digital photographs will be taken during the sampling.

Once the sample is collected, the sample and all QA/QC samples will be shipped to the selected laboratory for analysis. Sample handling (i.e., labeling, packaging, and shipping) and .CoC procedures will follow those detailed in Annex 19.

3.2 SEDIMENT SAMPLING I

The collection of the sediment sample will coincide with the surface water sampling activities and consist of the compositing of at least 10 subsamples collected from various areas of the streambed. Sediment samples will be collected in the shallow surface water locations from multiple braided channels using a clean, disposable plastic scoop. Sampling locations within the stream beds should be selected


3-1 May2017

where the surface water flow is low and/or deposition is most likely, such as bends in the creek as it changes direction. The sediment sampling procedure is as follows:

1. The individual performing the sampling will don clean gloves and prepare a disposable tray or sealable plastic bag and a plastic scoop.

2. Use a disposable scoop to remove the loose upper sediment uniformly from at least 10 subsample locations, starting downstream from the area to be sampled and moving upstream. Do not exceed 3 centimeters in depth into the sediment. Collect a sufficient quantity of sediment for QA/QC. ·

3. Pla~e sediment into a disposable tray or sealable plastic bag (e.g., Ziploc®).

4. Remove rocks, large pebbles, large twigs, leaves, or other debris.

5. Remove excess water from the sediment. This may require allowing the sample to settle.

6. Thoroughly mix (homogenize) the sediment within the disposable tray or bag.

7. Fill the appropriate sample containers.

8. Mark the sample location with a stake and log its coordinates using a DGPS unit.

9. Collect digital photographs and document data in the field logbook.

Additional details on the sediment sampling and the field procedures are provided in Annex 19. Once samples are collected, the samples and all QA/QC samples will be shipped to the selected laboratory for analysis. Sample handling (i.e., labeling, packaging, and shipping) and CoC procedures will follow those detailed in Annex 19.


3-2 May 2017

4.0 RESRAD CALCULATIONS

This section documents the dose assessment results for a hypothetical residential farmer receptor located on each RCA, as applicable, and for the same receptor scenario located at the nearest normally occupi_ed area, respectively. The dose assessments were completed to comply with license condition #19 ofNRC SML SUC-1593.

The dose assessments were conducted using the Residual Radiation (RESRAD 7.2) (Yu et al. 2016a) and RESRAD-OFFSITE 3.2 (Yu et al. 2016b) default residential farmer scenario pathways and parameters with the following exceptions:

• Nuclide-specific soil concentrations for U-238, U-235, and U-234 were calculated for each RCA by multiplying the entire mass of DU listed on the license for the installation (370 kg) by the nuclide-specific mass abundance, the nuclide specific activity, and appropriate conversion factors to obtain a total activity in picocuries (Table 4-1 ). That total activity was then assumed to be distributed homogenously in the top 6 inches (15 cm) of soil located within the area of the RCA.

Table 4-1. Specific Activity and Mass Abundance Values

S ecific Activit Mass Abundanceb

Nuclide Ci/g O/o

U-234 6.22 x 10·3 3.56 x 10-4

U-235 2.16 x 10"6 0.0938

U-238 3.36 x 10·7 99.9058

Depleted uranium• 3.6 x 10-7 100 a 10 CFR 20, Appendix B, Footnote 3. b Mass abundance calculations provided in Attachment 1.

• Non-default site-specific parameters applicable to both RESRAD and RESRAD-OFFSITE are listed in Table 4-2.

• Non-default site-specific parameters applicable only to RESRAD-OFFSITE are listed in Table 4-3.

• Groundwater flow was conservatively set in the direction of the offsite dwelling.


4-1 May 2017

4.1 RESRAD INPUTS

Table 4-2. Non-Default RESRAD/RESRAD-OFFSITE Input Parameters for Fort Polk RCA

Contaminated Zone

U-234

Soil concentrations (pCilg) U-235

U-238

Area of contaminated zone (m2)

Depth of contaminated zone (m)

Fraction of contamination that is submerged

Length parallel to aquifer flow (m)

Contaminated zone total porosity

Contaminated zone hydraulic conductivity (mly)

Contaminated zone b parameter

Average annual wind speed (mis)

Precipitation rate (annual rainfall) (mly)

Saturated Zone

Saturated zone total porosity

Saturated zone effective porosity

Saturated zone hydraulic conductivity (mly)

Saturated zone b parameter

Unsaturated Zone

Unsaturated zone I, total porosity

Unsaturated zone I, effective porosity

Unsaturated zone I, soil-specific b parameter

Unsaturated zone I, hydraulic conductivity (mly)

See Table 4-1.


NIA

NIA

NIA

10,000

2

0

100

0.4

IO

5.3

2.0

1.0

0.4

0.2

100

5.3

0.4

0.2

5.3

IO

3.64 x 10-2

Site-specific calculation based on the DU mass listed in the NRC 3.33 x 10-3 SML ='DU mass x nuclide specific mass abundance• x nuclide

0.55 specific activity• I (CZ area x CZ depth x CZ density)

1,000,000 One square kilometer

0.15 NRC SML SUC-1593, Item 11, Attachment 5

0 Depth to groundwater is generally I 0 to 30 ft bgs

1,000 Length of RCA is approximately 1,000 m

0.43 RESRAD Manual Table E-8 (DOE 2001) for Fine Sand (Soil is loamy fine sand from web soil survey)

4,930 RESRAD Manual Table E.2 (DOE 2001) for Loamy Sand

4.38 RESRAD Manual Table E.2 (DOE 2001) for Loamy Sand

6.5 www.usa.com for Fort Polk; LA

1.5 www.usa.com for Fort Polk, LA

0.43 RESRAD Manual Table E-8 (DOE 200 I) for Fine Sand

0.33 RESRAD Manual Table E-8 (DOE 2001) for Fine Sand


4.38 RESRAD Manual Table E.2 (DOE 200 I) for Loamy Sand

0.43 RESRAD Manual Ta~le E-8 (DOE 2001) for Fine Sand

0.33 RESRAD Manual Ta~le E-8 (DOE 200 I) for Fine Sand

4.38 RESRAD Manual Table E.2 (DOE 2001) for Loamy Sand


4-2 May 2017

Table 4-3. Non-Default RESRAD-OFFSITE Input Parameters for Fort Polk RCA

RCA Layout Parameter I Fort Polk Ranges 33 and 34A

Distance to nearest normally occupied area (m) 6,400

Bearing ofX axis (degrees) 0 (west)

X dimension of primary contamination (m) 1,000

Y dimension of primary contamination (m) 1,000

Location X Coordinate (m) Y Coordinate (m)

Smaller Larger Smaller Larger

Fruit, grain, non-leafy vegetables plot 500 531.25 7500 7532

Leafy vegetables plot 500 531.25 7534 7566

Pasture, silage growing area 500 600 7716 7816

Grain fields 500 600 7566 7666

Dwelling site 500 531.25 7400 7432

Surface-water body 500 800 7816 8116

'Atmospheric Transport Parameter

Meteorological ST AR file LA_ ALEXANDRIA.str

Groundwater Transport Parameter

Distance to well (parallel to aquifer flow) (m) 6,400

Distance to surface water body (SWB) (parallel to aquifer flow) (m) 6,816

Distance to well (perpendicular to aquifer flow) (m) 0

Distance to right edge ofSWB (perpendicular to aquifer flow) (m) -150

Distance to left edge ofSWB (perpendicular to aquifer flow) (m) 150

Anticlockwise angle from x axis to direction of aquifer flow 180 (degrees)

4.2 RESULTS

Table 4-4 presents the dose assessment results. Figure 4-1 presents graphs of the dose assessment results over the evaluation period. The calculated site-specific all pathway dose for e,ach RCA evaluated at Fort Polk does not exceed 1.0 x 10-2 milliSievert per year (mSv/y) (1.0 millirem per year [mrem/y]) total effective dose equivalent (TEDE) and meets license condition #19 of SML SUC-1593.

Table 4-4. RESRAD-Calculated Maximum Annual Doses for Resident Farmer Scenario

RCA~ a The onsite residential farmer receptor resides on the RCA. b The offsite residential farmer receptor resides off of the RCA, but within the installation, at the nearest normally occupied area.

RESRAD and RESRAD-OFFSITE output reports for each RCA are provided on the compact disk (CD).


4-3 May2017

4 .50E-03

4 .00E-03

3.50E-03

3 .00E-03 ... >- 2 .50E-03 "!; E 2 .00E-03 I E

1.50E-03

1 .00E-03

5 .00E-04

O.OOE+01 1

Figure 4-1. Residential Farmer Receptor Dose Graphs

Fort Polk Ranges 33 or 34A RCA Onsite (RESRAD)

DOSE: All Nuclides Summed, All Pathways Summed

10 100

Years

-G- U-23 4 ~ U-235 -Q..- U-23 8 -A- Total

I '

1000

I I 'I I

C\RESRAD_ FAM IL Y\RESRADl7.0\USERFILES\FCRT JACKSa.I RAflG.62 .RAD 0813012 01 6 08:52 ffiAPHI CS.ASC Incl udes All Pathway

0 .045

0 .040

0.035

0 .030 .

f 0 .025

~ E 0.020 ·

0 .015

0 .010

0.005 .

0 .000

RCA Offsite (RESRAD-OFFSITE)

DOSE: AllNuclides Summed,AllPathways Summed

10000

0 20000 40000 60000

Years

80000 100000

Rev ised Final Site-Specific ERM P Fort Po lk, Louisiana

-Q.- U-23 4 ~ U-235 ....Q.- U-238 ~ To tal

4-4 May 20 17

Attachmen't 1

Analysis of NRC's Default Value for Depleted Uranium Specific Activity


4-5 May2017


Each of the values of the relative mass abundances for the naturally occurring uranium isotopes in the legacy Davy Crockett depleted uranium on Army ranges helps determine the source terms for RESRAD calculations, the performance of which is a license condition. This note shows how I estimated them using the NRC default value for the specific activity of depleted uranium.

The third footnote to the tables in Appendix B ofTitle 10, Code of Federal Regulations (CFR), Part 20, "Standards for Protection Against Radiation," says, "The specific activity for ... mixtures of U-238, U-235, and U-234, if not known, shall be: SA= 3.6E·7 curies/gram U for LI-depleted." However, 10 CFR 20 does not describe how the NRC arrived at that value and I have not been able to learn this from NRC sources.

In general, the following equation provides the specific activity for a mixture of the three naturally occurring isotopes of uranium1 :

Sis the specific activity of the mixture of naturally occurring uranium isotopes, S1 is the specific activity

for uranium isotope i, a, is the relative molar mass abundance for uranium isotope i in the depleted uranium, and i denotes the uranium isotopes uranium-234 {734U), 735U and 738 U.

Rather than looking up each S; in a table, I calculated them from fundamental values to maximize accuracy. By definition, the specific activity for a particular isotope S, is the activity A1 per mass m1 for the isotope i. Also, by definition:

A.1 is the decay constant and N; is the number of atoms of uranium isotope Jin the sample with mass m~ Thus,

).. is related to the half-life t,.1as follows:

ln2 .1-=-

t t'hi

If M is set to Avogadro's number (N = 6.02 x 1023),2 then, by definition, m, is the mass of a mole of isotope i, given by lv[,, which is the atomic weight of isotope i with assigned units of grams. So,

Nln2 S-=--

1 ty,iM;

1 Although contaminants, including 236U, are possible, even likely, at levels l~ss than parts per million, I am not including contaminants in these calculations nor in the RESRAD calculations because of their negligible impact on the results. 2 In performing the calculations, I used all available significant digits in a spreadsheet. This note generally displays only two cir three significant digits In the equations. Minor discrepancies in calculated results are due to round-off.


4-6 May 2017


Values of the relative molar mass abundances, the half-lives, and the atomic weights for the naturally occurring uranium isotopes are available on a chart of the nuclides.3 The following table contains data used in calculations below:

Table - Isotopic Properties

Isotope Natural Relative Half-life Molar Mass Specific Activity"

Molar Mass Abundance (s) (g) (Bq g-1) (Ci g-1) 2J4u 0.000054 7.75x1012 234.04 2.30x 108 6.22x10-3

23su 0.007204 2.22x1016 235.04 7.99x104 2.lGx 10-6 2Jou 0.992742 1.41x1017 238.05 1.24x 104 3.36x 10-7

By definition:

1 = au.z:i.i + au.z35 + au.z3s

A second equation involves the ratio of au.234 to au.min depleted uranium. If ao.u.2:i.i is the natural relative mass abundance for 234U and ao,u.235 similarly fur 235U, then

au.z34 = ao.u-z34Du.z34 au.23s = ao.u-2JsDu.23s

Du.z34 is the depletion of234U in depleted uranium and Du.235 similarly for 235U, with

0 (complete depletion) s D, s 1 (no depletion)

Kolafa 5.estimated the depletion of 234U relative to the depletion of 235U as follows:

Du.234 = (1- 4s)n Du.23s = (1- 3s)"

e is the single stage enrichment efficiency per tfie difference of the uranium isotope atomic mass number from the atomic·mass numberof238U and is much less than one. n is the number of enrichment stages.

For large n:

Du-234 ~ e-4n" Du.23s ~ e-Jnc

Eliminate the product 11e by taking the logarithm of both equations:

In Du.234 = -4ns In Du-235 = -3ns

3 For example, see http://atom.kaeri.re.kr/nuchart/. 4 1 curie (Ci)= 3.7 x 1010 becquerels (Bq) 5 http:/lwww.ratical.om/radiation/lvzaifc/u234.html

Page 2of3


4-7 May2017


So,

Substituting for nc

4 lnDu-234 = 3lnDu-23s

Finally, exponentiating both sides of the equation,

So,

Thus,

rL _ D(4/3) ULJ-234 - U-235

- (4/3) au-2H - Clo.U-234DU-235

au-234 = (5.4· x 10-5)D5~m au.235 = (7.204 x 10-3)Du.235 au-230 = 1- (5.4 x 10-5)D5~{Jg- (7.204 x 10-3)Du.2;s

The NRC provides in 10 CFR 20:

S = 3.6 x 10-1 Ci g-1

Returning to the first equation above, then

(6.22 x 10-3 Ci g-1)(5.1 x 10-s)D5~m + c2.16 x 10-6 ci g- 1)(7.204- x 10-3)Du.23s

+ (3.36 x 10-1 Ci g-1 ) [ 1- cs.4 x 10-s)D5~m - (7 .204 x 10-3)Du-23s]

= 3.6 x 10-1 Ci g-1

Dividing by 10-7 Ci !f1 and collecting terms,

Solving, Dv-l:Jj "' 0. 13, and6

3.36D5~t:i + 0.131Du.m - 0.239 = 0

au.Z).I = 0.00000356 au-:m = 0.00093806 au.ns"' 0.99905838

•The values for " 4U and mu actually contain only one or two significant digits. I show more digits because I will use them in RESRAD calculations. Properly, the results should read au.m = 0.000004, au.m = 0.0009, and au:m = 0.9991. For comparison, typical isotopic abundanoes in depleted uranium according to the Department of Energy are au.234 = 0.000007, au.m = 0.0020, and au.ns = 0.9980 (DOE-STD-1136-2009), which corresponds to a specific activity of S = 3.8 x 10-7 Ci g-1• I note that the derived DOE value for Du.mis 0.13, which is inconsistent

with Kolafa's estimate calculated from the derived DOE value for Du.235: D~~ttJ = (0.2B)H/JJ = 0.10.


Page3 ofa

4-8 May 2017

5.0 REFERENCES

DOE (U.S. Department of Energy). 2001. User's Manual for RESRAD Version 6. July.

EA (EA Engineering, Science, and Technology, Inc.). 2013. Final Operational Range Assessment Program, Phase II Quantitative Assessment Report, Fort Polk, Louisiana.

IDQTF (Intergovernmental Data Quality Task Force). 2012. Uniform Federal Policy for Quality I Assurance Project Plans (UFP-QAPP) Manual, Optimized UFP-QAPP Worksheets. March.

NRC (U.S. Nuclear Regulatory Commission). 2016. Source Material License Number SUC-1593, Docket No. 040-09083. Amendment 1 (ADAMS Accession No. ML16039A234). March 21.

U.S. Army. 2014. Risk Management. Department of the Army Pamphlet (DA PAM) 385-30. Headquarters, Department of the Army, Washington, DC. December 2.

U.S. Army. 2015. Programmatic Approach for Preparation of Site-Specific Environmental Radiation Monitoring Plans (NRC ADAMS accession number ML16004A369).

USACE (U.S. Army Corps of Engineers). 2008. Final Installation Specific Archives Search Report on the Use of Cartridge, 20MM Spotting MlOl Davy Crockett Light Weapon M28 at Fort Polk, Louisiana. Revised. U.S. Army Corps of Engineers, St. Louis District. November.

Yu, C. et al. 2016a. RESRAD (onsite) (Version 7.2) [Computer Program]. Available at http://web.ead.anl.gov/resrad/RESRAD Family/ (Accessed August 24, 2016). July 20.

Yu, C .. et al. 2016b. RESRAD-OFFSITE (Version 3.2) [Computer Program]. Available at http://web.ead.anl.gov/resrad/RESRAD Family/ (Accessed July 14, 2016). June.


5-1 May 2017

REVISED FINAL

SITE-SPECIFIC ENVIRONMENTAL RADIATION MONITORING PLAN FORT RILEY, KANSAS ANNEX12


May2017

Submitted By:


Submitted To:


TABLE OF CONTENTS

Page


1.0 INTRODUCTION .......................................................................................................................... 1~1

I.I PURPOSE .............................................................................................................................. I-I . I.2 INSTALLATION BACKGROUND ...................................................................................... I-I 1.3 HISTORICAL INFORMATION ..................................................................................... : ..... I-5 1.4 PHYSICAL ENVIRONMENT .............................................................................................. 1-5 1.5 EVALUATION OF POTENTIAL SOURCE-RECEPTOR INTERACTIONS ..................... 1-7

2.0 ERMP SAMPLE DESIGN ............................................................................................................ 2-1

2.1 SURF ACE WATER AND SEDIMENT ..................... ~ .......................................................... 2-1 2.2 GROUNDWATER ................................................................................................................. 2-2 2.3 SOIL ....................................................................................................................................... 2-3

3.0 ERMP METHODOLOGY ............................................................................................................ 3-1

3.1 SURFACE WATER SAMPLING ......................................................................................... 3-1 3.2 SEDIMENT SAMPLING ...................................................................................................... 3-1



5.0 REFERENCES ............................................................................................................................... 5-1

LIST OF TABLES

Table I-1. Recommended ERM Sample Locations .......................................... , ........................................ I-1

Table 2-1. Uranium Surface Water Analytical Results ............................................................................. 2-2

Table 2-2. Uranium Groundwater Analytical Results (Detections Only) ................................................. 2-3

Table 4-1. Specific Activity and Mass Abundance Values ....................................................................... .4-1

Table 4-2. Non-Default RESRAD/RESRAD-OFFSITE Input Parameters for Fort Riley RCAs ............. .4-2

Table 4-3. Non-Default RESRAD-OFFSITE Input Parameters for Fort Riley RCAs ............................. .4-3

Table 4-4. RESRAD-Calculated Maximum Annual Doses for Resident Farmer Scenario ...................... .4-3

LIST OF FIGURES

Figure 1-1. Installation and Radiation Control Area Location Map .......................................................... 1-2

Figure 1-2. Radiation· Control Area (Ranges 27 A, 27B, and 29) and Proposed ERM Samples ................ 1-3

Figure 4-1. Residential Farmer Receptor Dose Graphs ............................................................................ .4-4

Revised Final Site-Specific ERMP Fort Riley, Kansas

iii May2017

. ASR bgs CD CFR CG Coe DGPS DoD DOE DU ELAP ERM ERMP gpm HASL ICP-MS IM COM kg LRU mz mrem/y mSv/y MOUT NRC ORAP PAERMP

PAL QA QC RCA RES RAD RSO SDAD SML SOP TA TEDE U-234 U-235 U-236 U-238 UFP-QAPP uxo


Archives Search Report Below Ground Surface Compact Disk Code of Federal Regulations Commanding General Chain-of-Custody Differential Global Positioning System U.S. Department of Defense U.S. Department of Energy Depleted Uranium · Environmental Laboratory Accreditation Program Environmental Radiation Monitoring Environmental Radiation Monitoring Plan Gallons per Minute Health and Safety Laboratory Inductively Coupled Plasma-Mass Spectroscopy Installation Management Command Kilogram Lower Range of Uncertainty Square Meters Millirem per Year MilliSievert per Year Military Operations in Urban Terrain U.S. Nuclear Regulatory Commission Operational Range Assessment Program Programmatic Approach for Preparation of Site-Specific Environmental Radiation Monitoring Plans Project Action Level Quality Assurance Quality Control Radiation Control Area Residual Radiation Radiation Safety Officer Surface Danger Area Diagram Source Material License Standard Operating Procedure Training Area Total Effective Dose Equivalent Uranium-234 Uranium-235 Uranium-236 Uranium-238 Uniform Federal Policy for Quality Assurance Project Plan Unexploded Ordnance


lV May2017

1.0 INTRODUCTION

This Site-Specific Environmental Radiation Monitoring Plan (ERMP) has been developed to fulfill the U.S. Army's compliance with license conditions #18 and #19 of the U.S. Nuclear Regulatory Commission (NRC) source material license (SML) SUC-1593 for the possession of depleted uranium (DU) spotting rounds and fragments as a result of previous use at sites located at U.S. Army installations. This Site-Specific ERMP is an annex to the Programmatic Approach for Preparation of Site-Specific ERMPs (PAERMP) (ML16004A369) (U.S. Army 2015) and describes the additional details related to Fort Riley, Kansas, in addition to those presented in the PAERMP. ·

1.1 PURPOSE

NRC issued SML SUC-1593 to the Commanding General (CG) of the U.S. Army Installation Management Command (IMCOM) authorizing the U.S. Army to possess DU related to historical training with the l 960s-era Davy Crockett weapons system at several installations nationwide. In order to comply with the conditions of the license, this Site-Specific ERMP has been developed to identify potential routes for DU transport and describe the monitoring approach to detect any off-installation migration of DU remaining from the use of the Davy Crockett weapons system at Fort Riley, Kansas. The installation will retain the final version of this Site-Specific ERMP. In accordance with license condition #19, the U.S. Army is required to implement fully this Site-Specific ERMP within 6 months of NRC approval. This Site-Specific ERMP and its implementation is then subject to NRC inspection. Table 1-1 summarizes the locations, media, and frequency of sampling described further in this Site-Specific ERMP.

Table 1-1. Recommended ERM Sample Locations

Sample Location I Sample Media I Sample Frequency

Co-located surface water and sediment samples downstream from the Range 29 RCA (HC-1) and from the Range 27A

and 27B RCA (SC-1), as shown in Figure 1-2 based on the rationale

presented in Section 2.1

Surface water and sediment based on the programmatic rationale presented in the P AERMP and

site-specific details presented in Section 2


Quarterly unless prevented by weather (e.g., frozen stream)

Fort Riley occupies approximately 101,732 acres in Riley, Geary, and Clay Counties, Kansas (Figure 1-1). Fort Riley provides training, readiness, and deployability for combat brigades and support for mobilization and deployment of Active Component and Reserve Component units. Training operations occur throughout the year on a daily basis at Fort Riley. Training includes field maneuvers, military operations in urban terrain (MOUT), use of combat vehicles, mortar and artillery fire, small arms fire, and aircraft flights (primarily helicopter). Fort Riley has a full infantry division composed of four brigades (Arcadis Malcom Pirnie 2013).

Fort Riley includes 92, 778 acres identified as operational range areas. Fort Riley has two - main Dudded Impact Areas encompassing 20, 147 acres; both are located just east of the installation's

center. One impact area encircles the other. There are 32 firing ranges surrounding the outer impact area. These include a demolition range, grenade ranges, gunnery ranges, mortar firing ranges, small arms ranges, and other ranges. Munitions use on the ranges includes small arms ammunition, medium- to large-caliber munitions, including high-explosive munitions and munitions with pyrotechnics and obscurants. Historical use of the range complex also included aerial rockets and bombs, and submunitions are known to have been used on about 75 percent of the central impact area. Tanks and Bradley fighting vehicles are used on the gunnery ranges.


1-1 May2017

Legend

l-:-.J Fort Riley Installation Boundary

c::::J Radiation Control Area

c::::J Oudded Impact Area

NA110NWIDE DU PROGRAM (DAVY CROCKETT)

U.S.A

INSTALLATION & RADIATION CONTROL AREA LOCATION MAP

FORT RILEY JUNCTION CITY, KS

DATE FIGURE

91812016 1-1


Rev ised Final Site-Specific ERMP Fort Ri ley, Kansas

1-2 May 2017

W~5"W


IA!l•nd

L-:-J Fort Riley lnstailation Boundary

CJ Radialion Control Alea

::::; 'Mtu.m.ed Boundary

CJ Dldded Impact Area

• ~g <>RAP Groundwater

+ surface 'Miler Flow Direction

surface wai.r & S.clment Sampling Loe1tlons

... =~.:~g,;,~·

... ::::ig,;,~i:· N<l

Figure 1-2. Radiation Control Area (Ranges 27A, 278, and 29) and Proposed ERM Samples

1-3

NATIONWIDE DU PROGRAM (DAVY CROCKETl)

U.S.A RADIATION CONTROL AREA (RANGES 27 A,

278 & 29) & PROPOSED ERM SAMPLES FORT RILEY

JUNCTION CITY, KS

DAT! ,.GU Re

!!11/2017 1-2

May 2017



1-4 May 2017

Training and maneuver areas, which surround the Dudded Impact Areas, are used to conduct coordinated maneuvers of troops and vehicles. Thi.s training can include live-fire training using blank ammunition or live rounds fired into the designated impact areas. There are 19 large training and maneuver areas (comprising 69,333 acres), which overlap a majority of the smaller training and maneuver areas. In addition, several MOUT ranges and other training areas are located within the training and maneuver areas (Arcadis Malcom Pirnie 2013).

The Revised Final Archives Search Report (ASR) (USACE 2008) indicated that the Davy Crockett weapon system was fielded and fired at Fort Riley, Kansas. Based on the collected information, two ranges, Range 29 and the Davy Crockett Range (former Range 27B, current Range 27), were identified as used for training with the Davy Crockett weapons (Figure 1-2). Although remnants of the Davy Crockett weapon system were not found at Fort Riley during the ASR inspection, the degree of confidence in the above conclusions is high (USACE 2008). The impact areas for the historical Davy Crockett ranges or the radiation control areas (RCAs), known as Ranges 27A and 27B and Range 29, are approximately 247 acres each. The nearest normally occupied area to Ranges 27 A and 27B is approximately 2.6 miles southeast of the RCA. The nearest normally occupied areas to Range 29 are approximately 4.2 miles south of the RCA.

1.3 HISTORICAL INFORMATION

The MlOl spotting round contained approximately 6.7 ounces of DU, and was a component of the 1960s-era Davy Crockett weapons system. Used for targeting accuracy, the MlOl spotting rounds emitted white smoke upon impact. The rounds remained intact or mostly intact on or near the surface following impact and did not explode. Remnants of the tail assemblies may remain at each installation where the U.S. Army trained with the Davy Crockett weapons system from 1960 to 1968. These installations include Fort Benning, Fort Bragg, Fort Campbell, Fort Carson, Fort Gordon, Fort Hood, Fort Hunter Liggett, Fort Jackson, Fort Knox, Fort Polk, Fort Riley, Fort Sill, Fort Wainwright, Joint Base Lewis-McChord (Fort Lewis and Yakima Training Area [TA]), Joint Base McGuire-Dix-Lakehurst (Frankford Arsenal Range), Schofield Barracks Military Reservation, and Pohakuloa TA.

The U.S. Army does not know if any cleanup or retrieval of these rounds or remnants has occurred at Fort Riley; therefore, it is assumed that most, if not all, of the 20 kilograms (kg) of DU from the rounds fired remains in the RCAs.


The general character of the area surrounding Fort Riley is rural with small farm communities. The lands north of Fort Riley support row crop and cereal grain production. The lands to the south are predominantly rangeland. The Republican, Smokey Hill, and Kansas Rivers form part of the southern boundary of the installation. Milford Lake, a 15,000-acre impoundment of the Republican River, forms part of the installation's western boundary.

Fort Riley lies within the Flint Hills section of the Central Lowlands physiographic province. It is bordered by the Great Plains on the west and the Ozark Plateau on the east. Terrain varies from alluvial bottomlands along the Republican and Kansas Rivers on the southern portion of the installation, through the hilly to steep lands in the central and east portions, to high uplands in the northern and western portions.

Fort Riley consists of three types oftopographical-physiographic area: 1) high upland prairies, 2) alluvial bottomland flood plains, and 3) broken and hilly· transition zones. The high upland prairies consist of alternating layers of very gently dipping (less than 1 degree) Permian limestone and shale. The


1-5 May 2017

uplands often contain various shale units that cover the escarpment-forming limestones. The cutting action of streams on the thick shale units has sculpted much of the area into a rolling pfateau. Two types · of alluvial bottomlands exist at Fort Riley: wide meandering floodplains of major rivers, with associated terraces; and areas created by smaller creeks and streams that cut the uplands. The transitional areas, extending from the uplands down to the valley floors are broken, sloping to steep country composed of alternating limestones and shales (U.S. Army 2007).

Fort Riley is part of the Great Plains Winter Wheat and Range Soil Resource Region. This region is covered with 1 foot or less of windblown material or loess. The loess rests upon alternating layers of weathered limestone and shale. Most soils are friable, silty loam 6 to 12 inches thick, overlying nearly impervious clays. Fort Riley's soils developed residually from parent materials and from other parent material carried by water or wind and then deposited. The permeability of the soils varies from excessively drained sandy lowland soils to tight clays with very slow permeability. Bedrock depths under those soils vary from less than 1 foot in upland areas to40 to 60 feet in many areas of the Main Post (U.S. Army 2007).

Waters on Fort Riley are surface water in rivers, other perennial and intermittent streams, ponds and lakes, and groundwater aquifers. The Republican and Kansas Rivers form the southern boundaries of Fort Riley. With the exception of oxbow lakes, the 174 lakes and ponds on Fort Riley are constructed impoundments. Aquifers receive water through alluvial deposits of streams and rivers, porous surface deposits, and fissured limestone in uplands by means of infiltration of rain and seepage from rivers into limestone and shale.

Surface waters at Fort Riley are located within the Kansas River basin. Nearly 145 miles of rivers and streams, consisting of 14 miles of rivers and 131 miles of streams, are present on Fort Riley. All 14 streams are intermittent except for Wildcat, Sevenmile, Madison, and Timber Creeks. Streams in the southern portion of Fort Riley drain to the south to the Republican or Kansas Rivers, which form the installation's southern boundary. Streams in the western portion of Fort Riley drain toward the southwest to Milford Lake on the Republican River. Streams in the northeastern portion of Fort Riley drain to Wildcat Creek, a perennial stream that runs along the northeastern boundary of the installation. Wildcat Creek ultimately drains to the Kansas River south of Manhattan.

Sevenmile Creek is downstream from the Ranges 27 A and 27B RCA and the central-southern portion of the Range 29 RCA. Sevenmile Creek is a perennial stream with a drainage basin of 17 .2 square miles in the Sevenmile Creek-Kansas River watershed (Figure 1-2). Sevenmile Creek flows southeast, discharging into the Kansas River. Honey Creek is downstream from the northern portion of the Range 29 RCA. Honey Creek drains approximately 6 square miles in the northern portion of the impact area in the Kitten Creek-Wildcat Creek watershed (Figure 1-2). Honey Creek flows eastward and discharges into Wildcat Creek. ·

Groundwater aquifers occur in the alluvial deposits of the major streams and rivers; in the porous surface deposits; and in the fissured, near-surface limestone of the upland areas. Saturated, water-bearing sediments in the Kansas River valley range from 0 to 90 feet in thickness. Well yields of 300 to 1,000 gallons per minute (gpm) are obtained from aquifer thicknesses of 20 to 40 feet, and yields in excess of .1,000 gpm can be obtained where aquifer thicknesses exceed 40 feet.

Moderate quantities of groundwater occur in the bedrock formations of the area, in particular the Fort Riley and Florence Limestone Formations. Where these limestones are fractured and/or contain solutioned cavities, well yields of 100 gpm or more can be obtained. Wells thll-t penetrate shales in the upland area will generally yield up to several gpm.


1-6 May 2017

Discharge from the valley-fill sediments, the major water-bearing deposits, is by seepage to major streams, evapotranspiration, and withdrawal by wells. Recharge of these deposits is by direct infiltration of precipitation, seepage from streams and ponds, return flow from irrigation, and seepage from the bedrock formations that border and underlie the valley (U.S Army 2007).


The transport of DU can be potentially completed along- the identified pathways to human and/or ecological receptors. Specific details regarding the potential receptors for Ranges 27 A and 27B and Range 29 at Fort Riley are as follows:

• Surface Water Use-In the intermediate aquifers, surface water infiltrates into the subsurface, particularly into the bedrock aquifers of the Towanda, Fort Riley, Florence, and/or Kinney

·Limestones, in which groundwater flows approximately west and is pumped by residential wells and wells located at Farnum Creek Campground. Groundwater samples were collected along this flow path during the Fort Riley Regional Range Study, and there were no detections of metals and/or explosives (USACHPPM 2007). However, the Regional Range Study did not include DU in the sampling event. In the alluvial aquifer, surface water runoff and/or local groundwater discharge into Sevenmile Creek (which flows off Fort Riley at the southeastern comer of the installation) recharges the Kansas River alluvial aquifer, from which groundwater is pumped by groundwater supply wells in the city of Ogden.

• Recreational Use-Milford Lake, the Republican River, the Kansas River, and many other area water bodies are used for fishing and boating. Fort Riley has 29 ponds and numerous streams and rivers, which are used for recreational fishing. All state regulations for fishing are in effect on Fort Riley, dictating season and creel limits on certain species of fish, turtles, crayfish, and frogs. The Kansas, Smoky Hill, and Republican Rivers on Fort Riley's southern boundary are also used for recreational fishing. Channel catfish (Ictalurus punctatus), flathead catfish (Pylodictis olivaris), white bass (Marone chrysops), striped bass (Marone saxatilis), hybrid

-white-striped bass (Marone sp.), walleye (Sander vitreus), carp (family Cyprinidae), freshwater drum (Aplodinotus grunniens), shovelnose sturgeon (Scaphirhynchus platorynchus), largemouth bass (Micropterus salmoides), and smallmouth bass (Micropterus dolomieu) are caught in the area's ponds, streams, and rivers. In addition, snapping and soft-shelled turtles, bullfrogs, and crayfish are taken from Fort Riley and the surrounding area and consumed.

• Sensitive Environments-There is no federal threatened or endangered species critical habitat identified on Fort Riley; however, Kansas has designated critical habitat on Fort Riley for four species: piping plover (Charadrius melodus), least tern (Sterna antillaru), sturgeon chub (Macrhybopsis gelida), and Topeka shiner (Notropis topeka). In 2000, the Kansas Department of Wildlife and Parks established state-designated habitat for the Topeka shiner, to include the main stem and tributary reaches of Wildcat, Little Arkansas, and Sevenmile Creeks. As of 2004, Honey, Wildcat, Wind, Little Arkansas, and Sevenmile Creeks were state-designated critical habitat for the Topeka shiner. Wildcat Creek and Sevenmile Creeks contain sections of statedesignated critical habitat for the Topeka shiner that are downstream from operational range areas. Riverine, lacustrine, and palustrine wetlands downgradient and downstream from Fort Riley operational range areas, including the Ranges 27 A and 27B and Range 29 RCAs, are also considered sensitive environments.

• Habitat-Habitats existing on Fort Riley may be divided into two main types: terrestrial and aquatic. Many species will use only one of these types; others will use both. Terrestrial habitats include native prairie, cool-season grassland, croplands planted as wildlife food plots or perimeter firebreaks, savanna, shelterbelts, and woodlands. Aquatic habitats include ponds, marshes, streams, reservoir coves, rivers, and sandbars. The least tern and piping plover critical habitat


1-7 May2017

has been designated as all waters within the corridor along the Kansas River's main stem. The sturgeon chub critical habitat has been designated as the Kansas River's main stem from its confluence with the Republican River and the Smoky Hill River to its confluence with the Missouri River. The Topeka shiner critical habitat has been designated as the Wildcat, Little Arkansas, and Sevenmile Creeks and their tributaries. Wetland habitats are also vital to many flora and fauna living on or in the vicinity of Fort Riley, including some state and federally listed species.

• Ecological Receptors-Three federally threatened or endangered species of animals are known to occur on Fort Riley. These species are considered representative of species downstream and downgradient from Fort Riley operational range areas. The Topeka shiner resides on Fort Riley for the entire year. The least tern and the piping plover are present rarely.

• Groundwater Use-Fort Riley and the surrounding communities primarily rely on groundwater from the alluvial aquifer along the Republican and Kansas Rivers for their primary source of drinking water, although some residential wells and production wells to the west of Fort Riley appear to be screened within intermediate bedrock aquifers of the Towanda, Fort Riley, Florence, and Kinney Limestone units. The surrounding communities that rely on groundwater for drinking water are Junction City to the south of the installation (population 20,000), Riley to the north (population 800), Grandview Plaza to the south (population less than 1,000), and Ogden to the southeast (population 1,600). The city of Manhattan (population 38,000) is about 7 miles northeast of southern Fort Riley along the Kansas River and obtains at least some of its water supply from the Kansas River alluvial aquifer. In addition, rural water districts within Riley and Geary Counties obtain their drinking water supply from the alluvial aquifer in the Kansas River Valley. Groundwater is also used for crop irrigation in the river valleys. Irrigation water use occurs mainly during the summer months. Fort Riley obtains its drinking water primarily from groundwater wells that are screened in the alluvial deposits. The Fort -Riley Main Post wells consist of eight wells located in alluvial deposits of the Republican River approximately 1 mile upstream from its confluence with the Smoky Hill River. Water levels in these water supply wells range from 15 to 25 feet below ground surface (bgs). There are groundwater wells used for domestic water supply that are located downgradient from Fort Riley within the 4-mile area (Malcolm Pirnie 2010).

Potential human receptors include recreational users of surface water bodies for fishing and swimming and those relying on potential public and private wells within 4 miles downgradient from Fort Riley for potable water. Ecological receptors include sensitive environments (e.g., Topeka shiner).


1-8 May2017


The PAERMP documented the conditions (i.e., "if-then" statements) for the sampling of each environmental medium to be used during the development of the Site-Specific ERMPs, and only environmental media recommended for sampling in the P AERMP are presented in the sections below. Per the PAERMP, no sampling will occur within the RCA or in the unexploded ordnance (UXO) areas (also referred to as Dudded Impact Areas). In addition, background/reference sampling is not required because the determination of DU presence will be based on an examination of the isotopic uranium ratios. The sampling approach and rationale for each medium for the RCAs (Ranges 27 A and 27B and Range 29) at Fort Riley are discussed in the following sections.


The surface water and sediment sampling approach will involve the collection of collocated samples from two locations downstream from the Ranges 27 A and 27B and Range 29 RCAs (Figure 1-2) where surface water flows throughout the year. If surface water is not flowing when a quarterly sampling event is planned (e.g., frozen stream, dry stream) or when sampling is too dangerous (e.g., rapid flow during flooding), no surface water samples will be collected during that event. Sediment samples will be collected on a quarterly basis unless sediment is inaccessible when a quarterly sampling event is planned (e.g., frozen stream, flooding).

The surface water and sediment sampling locations at Ranges 27 A and 27B and Range 29 were selected based on the surface water hydrology and potential for DU contribution and are located as follows:

• SC-1-The selected sampling point is located on Sevenmile Creek, downstream from the Ranges 27 A and 27B RCA and the southern portion of the Range 29 RCA. Sevenmile Creek is a perennial stream with a drainage basin of 17.2 square miles. Sevenmile Creek flows southeast, discharging into the Kansas River. The sampling location SC-1 is located upstream of the Kansas River and at the installation boundary.

• HC-1-The selected sampling point is located on Honey Creek, downstream from the northern portion of the Range 29 RCA. Honey Creek drains approximately 6 square miles in the northern portion of the impact area and drains numerous small arms firing ranges north of the impact area. Honey Creek flows eastward and discharges into Wildcat Creek. The sampling location HC-1 was located immediately upstream of the confluence with Wildcat Creek and within the installation boundary.

The proposed surface water and sediment sampling at SC-1 and HC-1 is focused on Sevenmile Creek-Kansas River and Kitten Creek-Wildcat Creek watersheds because they are downstream from the RCAs. TC-1 (Timer Creek) is a reference location that was sampled during the Operational Range Assessment Program (ORAP) and is not downstream from the RCAs.

Surface water and sediment samples will be analyzed for total/isotopic uranium using U.S. Department of Energy (DOE) Health and Safety Laboratory (HASL) method 300 (alpha spectrometry). Further details on analytical procedures and quality assurance/quality control (QA/QC) information are presented in Annex 19. When analytical sampling results from locations outside the RCA indicate that the uranium-238 (U-238) /uranium-234 (U-234) activity ratio exceeds 3.0, the U.S. Army will notify NRC within 30 days and collect additional surface water and sediment samples within 30 days of the notification to NRC, unless prohibited by the absence of the sampling media. The analytical samples displaying an activity ratio exceeding 3.0 will be reanalyzed using inductively coupled plasma-mass


2-1 May2017

spectroscopy (ICP-MS) for their U-234, uranium-235 (U-235), and U-238 content to calculate the U-235 weight percentage specified in 10 Code of Federal Regulations (CFR) § 110.2 (Definitions) and then to determine if the sample results are indicative of totally natural uranium (at or about 0. 711 weight percent U-235) or DU mixed with natural uranium (obviously less than 0.711 weight percent U-235).

Surface water flow in the s,treams on Fort Riley is expected to vary on the scales of hours, days, and years depending on precipitation rates over the same time scales. The surface water and sediment sampling can be conducted on the PAERMP's specified quarterly interval. The highest stream flows (wet season) typically occur in May with the lowest flows (dry season) in December (Malcom Pirnie 2010). ·

Surface water at the recommended downstream sampling locations (HC-1 and SC-1) for the environmental radiation monitoring (ERM) and upstream reference location were sampled during the ORAP Phase II assessment in April and June 2010 (Arcadis Malcolm Pirnie 2013). The results of the April and June sampling event are presented in Table 2-1.

Table 2-1. Uranium Surface Water Analytical Results

Sample Location I Number of Samples I Range of Concentrations (1tg/L) HC-I 2 1.52-2.44

HC-1 (dissolved) 2 1.46-2.36 SC-I 2 0.97I-2.37

SC-I (dissolved) 2 0.48I-2.54 TC-I 2 2.56-3.36

TC-I (dissolved) 2 2.54-3.28

2.2 GROUNDWATER

Twenty-six groundwater samples were collected and analyzed for uranium (all 26 were analyzed for total and isotopic uranium and 12 of the 26 samples were analyzed for dissolved uranium) during the ORAP Phase II assessment in May 2010 (Arcadis Malcom Pirnie 2013). The results of the May 2010 sampling event are presented in Table 2-2. The existing groundwater monitoring wells are shown in Figure 1-2.

Total uranium was detected in 25of26 groundwater samples collected during the ORAP Phase II assessment. None of the samples contained total uranium at a concentration that exceeded the project action levels (PALs); however, groundwater samples GWSE-BW2-GW-01 and GWSE-CFW-GW-03 had concentrations that were greater than the lower range of uncertainty (LRU). The remaining detected concentrations of total uranium were generally two orders of magnitude less than the PAL and one order of magnitude less than the LRU. Dissolved uranium was detected in all 12 groundwater samples analyzed.

Total uranium concentrations in groundwater may be due to both naturally occurring sources and range-related sources; therefore, the groundwater samples also were analyzed for isotopic uranium (U-234, U-235/uranium-236 [U-236], U-238) to determine if the total uranium was due to naturally occurring sources, range-related sources, or a combination of the two sources. U-234 and U-238 typically have equivalent radioactivities in naturally occurring uranium (e.g., both U-234 and U-238 account for approximately 48.9 percent of the radioactivity), but U-238 is elevated relative to U-234 in DU (USEPA 2006). The isotopic uranium results indicate that the U-234 radioactivity is greater than the U-238 radioactivity for both of the groundwater samples that had total uranium concentrations greater than the LRU. Because the results indicate that U-238 radioactivity is less than U-234, the total uranium detected in the groundwater samples appears to be due to naturally occurring sources and does not have a rangerelated source (Arcadis Malcom Pirnie 2013).


2-2 May 2017

Table 2-2. Uranium Groundwater Analytical Results (Detections Only)

Sample Location (Depth) I Result (11g/L)

A W-1 (18-20') Total 4. 79 I Dissolved 4.6

AW-1 (28-30') Total 5.33 I Dissolved 3.72

BW-1 (75-85') Total 1.61 I Dissolved 1.3 8

BW-1(103-113') Total 1.56 I Dissolved 1.1

BW-1 (160-170') Total 7 I Dissolved 1.57

BW-2 (85-95') Total 4.71 JI Dissolved 2.48 J

BW-2 (155-165') Total 1.64 J I Dissolved 1.52 J

BW-2 (l 72-182') Total 4.71IDissolved2.78

BW-2 (220-230') Total 20.3 J I Dissolved 2.63 J

BW-3 (85-95') Total 1.34 I Dissolved 1.27

BW-3 (170-180') Total 1.94 I Dissolved 1.67

BW-3 (130-140') Total 1.76 JI Dissolved 1.19 J

CF98-601 (19-29') Total 4.23 J

CF97-103 (59-69') Total 4.26 J

CF97-101 (13.5 - 23.5') Total 20 J

CF97-401 (16.20-26.20') Total 1.56 J

SFL97-903 (43.80-53.80') Total 3.41 J

337085 (I 10-130') Total 3.55 J

CF99-901 (13.05-23.05') Total 5.73 J

GW Prod Well #9 (NIA) Total 6.63 J

IZ92-00I (50-60') Total 4.62 J

IZ92-002 (52-62') Total I J

IZ92-003 (123-143') Total I.OJ

IZ92-012 (35-45') Total 2.2 J

Presently, no groundwater monitoring wells are located at or near the RCA. Since surface water is known to recharge groundwater, any DU potentially present in surface water that could impact groundwater will likely be detected through surface water and sediment sampling. For these reasons and the additional rationale included in the PAERMP (U.S. Army 2015), groundwater sampling is not planned for Fort Riley.

2.3 SOIL


routine operations and maintenance activities, the U.S. Army will sample that deposit semiannually with one sample taken per 25 m2 unless the soil erosion is located in a UXO area. The collection of ERM samples in UXO areas generally will not occur. Exceptions will occur only with documented consultation among the License Radiation Safety Officer (RSO), installation safety personnel, and range control personnel, who will advise the Installation Commander (i.e., they will prepare a formal risk assessment in accordance with U.S. Army [2014]). The Installation Commander will then decide whether to allow the collection. Otherwise, RCAs for Ranges 27 A and 27B and Range 29 do not meet any other criteria that would require soil sampling in accordance with the PAERMP (U.S. Army 2015).


2-3 May 2017

Prior to mobilization; field sampling personnel will contact Range Control, the Installation RSO, or designee to determine if erosional areas within the RCAs have been identified and, if so, sampled in accordance with requirements in Section 3.0 and Annex 19.


2-4 May2017

3.0 ERMP METHODOLOGY.

The sampling and laboratory analysis procedures to be utilized during the ERM are described below. These procedures provide additional details and required elements to support the Site-Specific ERMP and must be utilized in conjunction with the standard operating procedures (SOPs) during execution of ERM activities. This Site-Specific ERMP is to be used in conjunction with Annex 19, which addresses programmatic requirements associated with ERM sampling, such as chain-of-custody (CoC), packaging for shipment, shipping, collecting field QC samples (e.g., field duplicate samples), and documenting potential variances from sampling procedures. Annex 19 has been prepared in accordance with guidance from the Uniform Federal Policy for Quality Assurance Project Plan (UFP-QAPP) Optimized Worksheets (IDQTF 2012). All entry to Fort Riley will be coordinated with the Fort Riley Installation Safety Office and Range Control prior to mobilizing for fieldwork.

Only a laboratory that the U.S. Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) has accredited for uranium analysis using both alpha spectrometry and ICP-MS methods will perform radiochemical analyses for the purposes ofNRC license compliance. The U-238 to U-234 activity ratio and the weight percent U-235 are used to determine whether a given sample is indicative of natural uranium or DU. The laboratory will use alpha spectrometry to analyze samples for U-234 and U-238 activities in order to comply with license condition #17 in NRC SML SUC-1593. All samples with U-238/U-234 activity ratios exceeding 3.0 will be reanalyzed using ICP-MS for their U-234, U-235, and U-238 content to identify samples with DU content (NRC 2016). The ICP-MS results for U-234, U-235, and U-238 are summed to calculate a total mass of uranium present, which will be used to establish the weight percent U-235 and then to determine ifthe sample results are indicative of totally natural uranium (at or about 0.711 weight percent U-235) or DU mixed with natural uranium (obviously less than 0.711 weight percent U-235). Additional details about the sampling and analysis to support this Site-Specific ERMP are included in Annex 19.


Surface water samples will be collected at HC-1 and SC-1 and submitted for laboratory analysis. The grab surface water samples will be collected using disposable equipment (e.g., tubing) or collected directly into sample containers. Details of the surface water sampling and the associated field procedures are provided in Annex 19.

Sampling activities, including documentation of the site conditions and the sample details, will be included within the field logbook. Following the sampling, each location will be surveyed with a differential global positioning system (DGPS) unit to identify the location with sub-meter accuracy and documented in the field logbook. Digital photographs will be taken during the sampling.

Once samples are collected, the samples and all QA/QC samples will be shipped to the selected laboratory for analysis. Sample handling (i'.e., labeling, packaging, and shipping) and CoC procedures will follow those detailed in Annex 19. '

3.2 SEDIMENT SAMPLING

The collection of sediment samples will coincide with the surface water sampling activities and consist of the compositing of at least 10 subsamples collected from various areas of the stream bed. Sediment samples will be collected in the shallow surface water locations using a clean, disposable plastic scoop. Sampling locations within the stream beds should be selected where the surface water flow is low


3-1 May 2017

and/or deposition is most likely, such as bends in the creek as it changes direction. The sediment sampling procedure is as follows:

1. The individual performing the sampling will don clean gloves and prepare a disposable tray or sealable plastic bag and a plastic scoop:

2. Use a disposable scoop to remove the loose upper sediment uniformly from at least 10 subsample locations, starting downstream from the area to be sampled and moving upstream. Do not exceed 3 centimeters in depth into the sediment. Collect a sufficient quantity of sediment for QA/QC.

3. Place sediment into a disposable tray or sealable plastic bag (e.g., Ziploc®).





8. Mark the sample location with a stake and log its coordinates using a DGPS unit.


Additional details on the sediment sampling and the field procedures are provided in Annex 19. Once samples are collected, the samples and all QA/QC samples will be shipped to the selected laboratory for analysis. Sample handling (i.e., labeling, packaging, and shipping) and CoC procedures will follow those detailed in Annex 19.


3-2 May2017


This section documents the dose assessment results for a hypothetical residential farmer receptor located on each RCA, as applicable, and for the same receptor scenario located at the nearest normally occupied area, respectively. The dose assessments were completed to comply with license condition #19 ofNRC SML SUC-1593.

The dose assessments were conducted using the Residual Radiation (RESRAD) 7.2 (Yu et al. 2016a) and RESRAD-OFFSITE 3.2 (Yu et al. 2016b) default residential farmer scenario pathways and parameters with the following exceptions:

• Nuclide-specific soil concentrations for U-238, U-235, and U-234 were calculated for each RCA by multiplying the entire mass of depleted uranium listed on the license for the installation (20 kg) by the nuclide-specific mass abundance, the nuclide specific activity, and appropriate conversion factors to obtain a total activity in picocuries (Table 4-1 ). That total activity was then assumed to be distributed homogenously in the top 6 inches (15 cm) of soil located within the area of the RCA.


Nuclide Specific Activity Mass Abundance"

Ci/g

U-234 6.22 x 10-3 3.56 x 10-4

U-235 2.16 x 10-6 0.0938

U-238 3.36 x 10-7 99.9058

Depleted uranium• 3.6 x 10-7 100 ' I 0 CFR 20, Appendix B, Footnote 3 b Mass abundance calculations provided in Attachment I.



• Groundwater flow was conservatively set in the direction of the off site dwelling.


4-1 May2017

4.1 RESRAD INPUTS

Table 4-2. Non-Default RESRAD/RESRAD-OFFSITE Input Parameters for Fort Riley RCAs

Parameter

Internal dose library DCFPAK

Contaminated Zone

U-234 Soil concentrations

U-235 (pCi/g)

U-238

Area of contaminated zone (m2)

Depth of contaminated zone (m)

Fraction of contamination that is submerged

Length parallel to aquifer flow (m)

Contaminated zone total porosity

Contaminl!ted zone hydraulic conductivity (m/y)

Contaminated zone b parameter

Average annual wind speed (m/s)

Precipitation rate (annual rainfall) (m/y)

Saturated Zone

Saturated zone total porosity

Saturated zone effective porosity

Saturated zone hydraulic conductivity (m/y)

Saturated zone b parameter

Unsaturated ione

Unsaturated zone I, total porosity

Unsaturated zone l, effective porosity

Unsaturated zone 1, soil-specific b parameter

Unsaturated zone I, hydraulic conductivity (m/y)

See Table I.


3.02

NIA NIA NIA

10,000

2

0

100

0.4

10

5.3

2.0

l.O

0.4

0.2

100

5.3

0.4

0.2

5.3

10

.lustillcation or Source

Conservative dose coefficients for site contaminants

1.97 x 10-3 l.97 x 10-3 Site-specific calculation based on the DU mass listed in

1.8 x 10-4 l.8xl0-4 the NRC SML = DU mass x nuclide specific mass abundance' x nuclide specific activity'/ (CZ area x CZ

0.03 0.03 depth x CZ density)

1,000,000 1,000,000

0.15 0.15 NRC SML SUC-1593, Item I I, Attachment 5

0 0 Phase I Periodic Review document (U.S. Army 2014) indicates depth to groundwater is I 0 ft bgs

1,000 1,000 Length of RCA is approximately 1,000 m

RESRAD Manual Table E.8 (DOE 2001) for Silt (Soil 0.45 0.45 is Silty Loam for Ranges 27 A and 278; soil is Silty Clay

Loam for Range 29; determined from web soil survey)

227 53.6 RESRAD Manual Table E.2 (DOE 2001) for Silty Loam or Silty Clay Loam

5.3 7.75 RESRAD Manual Table E.2 (DOE 2001) for Silty Loam or Silty Clay Loam

7.7 7.7 www.usa.com for Fort Riley, KS

0.8 0.8 www.usa.com for Fort Riley, KS

0.45 0.45 RESRAD Manual Table E-8 (DOE 2001) for Silt


227 53.6 RESRAD Manual Table E.2 (DOE 2001) for Silty Loam or Silty Clay Loam

5.3 7.75 RESRAD Manual (DOE 200 l) Table E.2 for Silty Loam or Silty Clay Loam



5.3 7.75 RESRAD Manual (DOE 200 l) Table E.2 for Silty Loam or Silty Clay Loam

227 53.6 RESRAD Manual Table E.2 (DOE 200 l) for Silty Loam or Silty Clay Loam

4-2 May2017

Table 4-3. Non-Default RESRAD-OFFSITE Input Parameters for Fort Riley RCAs

RCA Layout Parameter Ranges 27 A and 27B Range 29

Distance to nearest normally occupied area 3,800' 2,500 (m)

Bearing of X axis (degrees) l 80(east) l 35(northeast)

X dimension of Primary Contamination (m) 1,000 1,000

Y dimension of Primary Contamination (m) 1,000 1,000

Location X Coordinate (m) Y Coordinate (m) X Coordinate (m) Y Coordinate (m}

Smaller Larger Smaller Larger Smaller Larger Smaller

Fruit, grain, non-leafy vegetables plot 500 53 l.25 4900 '4932 500 53 l.25 3600

Leafy vegetables plot 500 531.25 4934 4966 500 53 l.25 3634

Pasture, silage growing area 500 600 5116 5216 500 600 3816

Grain fields 500 600 4966 5066 500 600 3666

Dwelling site 500 53 l.25 4800 4832 500 531.25 3500

Surface-water body 500 800 5216 5516 500 800 3916

'Primary' Contamination Parameter ' 'Length parallel to aquifer flow* 1000 255

Atmospheric Transport Parameter · ·

Meteorological ST AR file KS_TOPEKA.str KS_TOPEKA.str

Groundwater Transport Parameter Distance to well (parallel to aquifer flow)

3800 2500 (m) Distance to surface water body (SWB)

4216 2916 (parallel to aquifer flow) (m) Distance to well (perpendicular to aquifer

0 0 flow) (m) Distance to right edge of SWB

-150 -150 (perpendicular to aquifer flow) (m) Distance to left edge of SWB (perpendicular

150 150 to aquifer flow) (m) Anticlockwise angle from x axis to direction

0 315 of aquifer flow (degrees) * Conservative value selected to maximize groundwater concentration and ensure that volumetric groundwater flow

rate under the Contaminated Zone (CZ) exceeds or meets the recharge volumetric rate through the CZ.

4.2 RESULTS

Larger

3632

3666

3916

3766

3532

4216

Table 4-4 presents the dose assessment results. Figure 4-1 presents graphs of the dose assessment results over the evaluation period. The calculated site-specific all pathway dose for each RCA evaluated at Fort Riley does not exceed 1.0 x 10-2 milliSievert per year (mSv/y) (1.0 millirem per year [mreriJ./y]) total effective dose equivalent (TEDE) and meets license condition #19 of SML SUC-1593.


Fort Rile Range 29 3.5 x 10-3 1.2 x 10-3

• The onsite residential farmer receptor resides on the RCA. b The offsite residential farmer receptor resides off of the RCA, but within the installation, at the nearest normally occupied area.



4-3 May 2017

3 .SOE-03

3 .00E-03

2 .SOE-03

~ 2 .00E-03 1

E: E E 1 .SOE-03

1 .00E-0 3

5 .00E-04 ·

Figure 4-1. Residential Farmer Receptor Dose Graphs

Fort Riley Ranges 27 A and 27B RCA Onsite (RESRAD)

DOSE: All Nuclides Summed, A II Pathways Summed

I I I

'+

0 .00 E+01 ,_..--.,----E;~~"T"-~"'!""'1"9-----'-__jQ.-_ _.__--'_r::~----L-..4..J.?--r-r

1

1.40E-03

1.20E-03

1 .00E-03

.... 8 .00E-04 >.

E: E E 6 .00E-04 •

4 .00E-04

2.00E-04

0 .00E+01 0

Revised Final Site-Specific ERMP Fort Ri ley, Kansas

10 100

Years

-0-- U·23 4 ~ U·235 -C- U-236 -A- Total


DOSE: AllNuclides Summed , A II Pathways Summed

20000 40000 60000

Years

80000

-G- U-23 4 + U-235 -C- U-238 --8- Tolal

4-4

100000

May 20 17

3.SOE-03

3.00E-03

2 .SOE-03

.... 2.00E-03 >-

~ I!! E 1 .SOE-03

1 .00E-03

5 .00E-04

O.OOE+01

1 AOE-03

1 .20E-03

1 .00E-03

.... 8 .00E-04 >-

~ I!! E 6 .00E-04

4.00E-04

2.00E-04

O.OOE+01 0

Revised Final Site-Specific ERM P Fort Riley, Kansas

Fort Riley Range 29 RCA Onsite (RESRAD)

DOSE: AllNuclides Summed, A II Pathways Summed

10 100

Years

-G- U-23 4 + U-235 _g._ U·238 -A- Total


DOSE: AllNuclides Summed ,AllPathways Summed

20000 40000 60000

Years

80000

-G- U-23 4 + U-235 _g._ U·238 -A- Total

4-5

100000

May20 17


.. ;·

Attachment 1

Analysis ofNRC's Default Value for Depleted Uranium Specific Activity


4-7 May 2017


Each of the values of the relative mass abundances for the naturally occurring uranium isotopes in the legacy Davy Crockett depleted uranium on Army ranges helps determine the source terms for RESRAD

calculations, the performance of which is a license condition. This note shows how I estimated them using the NRC default value for the specific activity of depleted uranium.

The third footnote to the tables in Appendix B ofTitle 10, Code of Federal Regulations (CFR), Part 20, "Standards for Protection Against Radiation," says, "The specific activity for ... mixtures of U-238, U-235, and U-234, if not known, shall be: SA= 3.6E-7 curies/gram U for U-depleted." However, 10 CFR 20 does not describe how the NRC arrived at that value and I have not been able to learn this from NRC sources.

In general, the following equation provides the specific activity for a mixture of the three naturally occurring isotopes of uranium':

S= LS;a1 I

Sis the specific activity of the mixture of naturally occurring uranium isotopes, S, is the specific activity for uranium isotope i, u, is the relative molar mass abundance for uranium isotope i in the depleted uranium, and i denotes the uranium isotopes uranium-234 (234U), 235U and 738U.

Rather than looking up each S1 in a table, I calculated them from fundamental values to maximize accuracy. By definition, the specific activity for a particular isotope S, is the activity A, per mass m, for

the isotope i. Also, by definition:

,l, is the decay constant and Mis the number of atoms of uranium isotope /in the sample with mass m;.

Thus,

,l, is related to the half-life t,.,as follows:

ln2 .l1=

t'hi

If N, is set to Avogadro's number (N = 6.02 x 10"').2 then, by definition, m, is the mass of a mole of isotope i, given by lvJ,, which is the atomic weight of isotope i with assigned units of grams. So,

Nln2 s,=-ty,;M1

1 Although contaminants, including ""U, are possible, even likely, at levels less than parts per million, I am not including contaminants in these calculations nor in the RESRAD caiculations because of their negligible impact on

the results. 2 In performing the calculations, I used all available significant digits in a spreadsheet. This note generally displays only two or three significant digits in the equations. Minor discrepancies in calculated results are due to round-<lff.


4-8 May2017


Values of the relative molar mass abundances, the half-lives, and the atomic weights for the naturally

occurring uranium isotopes are available on a chart of the nuclides.3 The following table contains data used in calculations below:


Isotope Natural Relative Half-life Molar Mass Specific Activity4

Molar Mass Abundance (s) (g) (Bqg-1) (Ci g-1) 234u 0.000054 7.75x1012 234.04 2.30x108 6.22X 10"3

mu 0.007204 2.22x 101t; 235.04 7.99x104 2.16x 10~ 238u 0.992742 1.41x 1017 238.05 1.24x104 3.36x 10·7

By definition:

1 = CIU-234 + CIU·Z3~ + CIU-238

A second equation involves the ratio of au.234 to au.m in depleted uranium. If ao,u.23-1 is the natural relative mass abundance for 234U and ao,u-m similarly for 235 U, then

au.234 = ao,u-234Du.234 au.zJs = ao,u-23sDu.2Js

Du.234 is the depletion of 234U in depleted uranium and Du.m similarly for 235U, with

0 (complete depletion) SD, S 1 (no depletion)

Kolara5 estimated the depletion of. 234U relative to the depletion of 235U as follows:

Du.234 = (1 - 4sr Du.m = (1 - 3s)n

e is the single stage enrichment efficiency per the difference of the uranium isotope atomic mass number from the atomic mass number of 238 U·and is much less than one. n is the number of enrichment

stages.

For large n:

Du.234 _,. e-4nE

Du.235 -.. e-Jnc

Eliminate the product 11.:by taking the logarithm of both equations:

In Du.234 = -4ns lnlJu.235 = -3ne

'For example, see http:ljatom.kaeri re.kdnuchart/. 4 1 curie (Ci)= 3.7 x 1010 .becquerels (Bq) 5 http://www.ratical.org/radiation//yzaiic/u234.html

Page 2 of 3


4-9 May2017


So,

Substituting for ne

. 4 lnDu.234 =31nDu.23s

Finaliy, exponentiating both sides of the equation,

So,

Thus,

fL - (4/3) "U-234 - /Jjj.z35

(4/3) au.234 = ao.u-231Du.z35

au-m = (5.4 x 10-5)D5~{{~ au.z35 = (7.204 x 10-3)Du.z35 au.238 = 1- (5.4 x 10-5)D5~£IJ - (7.204 X 10-3)Du.235


S = 3.6 x 10-1 Ci g-1


(6.22 x 10-3 Ci g-1)(5.4 x 10-5)D5~m + (2.16 x 10-6c1g- 1)(7.204x10- 3 )Du-23s

+ (3.36 x 10-1cig- 1 )(1- cs.4x 10- 5)D5~m-<7.204x10-3)Du.m] = 3.6 x 10-1 c1 g-1

Dividing by 10-7 Ci g·1 and collecting terms,

Solving, Du-n' = 0.13, and6

336D5~m + o.131Du.z3s - 0.239 = o

au.ZJ.l = 0.00000356 au-2:1' "" 0.00093806 au.236 = 0.99905838

6 The values for "'U and mu actually contain only one or two significant digits. I show more digits because I will use them In RESRAD calculations. Properly, the results should read au.lJ• = 0.000004, au-23s = 0.0009, and au-238 0.9991. For comparison, typical isotopic abundances in depleted uranium according to the Department of Energy are au.n4 = 0.000007, au.m = 0.0020, and au.n8 = 0.9980 (DOE-STD-1136-2009), which corresponds to a specific activity of S • 3.8 x 11)"'7 Ci g-1• I note that the derived DOE value for Du.lJ• is 0.13, which is inconsistent

with Kolafa's estimate calculated from the derived DOE value for Du-ns: D~:f;J = (o.20)<"1t 3> = 0.18.


Page 3 of 3

4-10- May 2017

--------- -- -----------

5.0 REFERENCES

Arcadis Malcom Pirnie. 2013. Final Operational Range Assessment Program, Phase II Assessment Report, United States Army Garrison Fort Riley, Kansas.


IDQTF (Intergovernmental Data Quality Task Force). 2012. Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) Manual, Optimized UFP-QAPP Worksheets. March.

Malcom Pirnie. 2010. Final Quality Assurance Project Plan Operational Range Assessment Program, Phase II Quantitative Assessment, United States Army Garrison Fort Riley, Kansas.


U.S. Army. 2007. Programmatic Environmental Assessment Military Engineering, Fort Riley, Kansas. http://www.riley.army.mil/Portals/O/Docs/Services/RileyServices/Environmental/Military%20En gineering%20EA %201 %20.pdf.


U.S. Army. 2015. Programmatic Approach for Preparation of Site-Specific Environmental Radiation Monitoring Plans (NRC ADAMS accession number ML16004A369).

USACE (U.S. Army Corps of Engineers). 2008. Final Installation Specific Archive Search Report on the Use of Cartridge, 20MM Spotting MlOl Davy Crockett Light Weapon M28 at Fort Riley, Kansas. Revised. U.S. Army Corps of Engineers, St. Louis District. August.

USEPA (U.S. Environmental Protection Agency). 2006. Depleted Uranium Technical Brief, EPA-402-R-06-011.


Yu, . C. et al. 2016b. RESRAD-OFFSITE (Version 3.2) [Computer Program]. Available at http://web.ead.aril.gov/resrad/RESRAD Family/ (Accessed July 14, 2016). June.


5-1 May 2017

REVISED FINAL

SITE-SPECIFIC ENVIRONMENTAL RADIATION MONITORING PLAN POHAKULOA TRAINING AREA, HA WAii ANNEX17


April 2017

Submitted By:


Submitted To:


t ABLE OF CONTENTS

Page


1.0 INTRODUCTION .......................................................................................................................... 1-1

1.1 PURPOSE , ............................................................................................................................. 1-1 1.2 INSTALLATION BACKGROUND ...................................................................................... 1-1 1.3 HISTORICAL INFORMATION ........................................................................................... 1-5 1.4 PHYSICAL ENVIRONMENT .............................................................................................. 1-5 1.5 EVALUATION OF POTENTIAL SOURCE-RECEPTOR INTERACTIONS ..................... 1-5

2.0 ERMP SAMPLE DESIGN ............................................................................................................ 2-1

2.1 SURFACE WATER AND SEDIMENT ................................................................................ 2-1 2.2 GROUNDWATER ......... .' ....................................................................................................... 2-1 2.3 SOIL ....................................................................................................................................... 2-1

3.0 ERMP METHODOLOGY ........................................................................................................•... 3-1

3.1 SURFACE WATER SAMPLING ........................................................ , ................................ 3-1 3.2 SEDIMENT SAMPLING ...................................................................................................... 3-1



5.0 REFERENCES ............................................................................................................................... 5-1

LIST OF TABLES

Table 1-1. Recommended ERM Sample Location .................................................................................. 1-1

Table 4-1. Specific Activity and Mass Abundance Values .................................................................... .4-1

Table 4-2. Non-Default RESRAD/RESRAD-OFFSITE Input Parameters for Pohakuloa Training Area RCAs ............................................................................................................... 4-2

Table 4-3. Non-Default RESRAD-OFFSITE Input Parameters Pohakuloa Training Area RCAs .......... 4-3

Table 4-4. RESRAD-Calculated Maximum Annual Doses for Resident Farmer Scenario .................... .4-4

LIST OF FIGURES

Figure 1-1. Installation and Radiation Control Area Location Map ......................................................... 1-2

Figure 1-2. Radiation Control Area (Pohakuloa) and Proposed ERM Samples ....................................... 1-3

Figure 4-1. Residential Farmer Receptor Dose Graphs for Pohakuloa Training Area RCAs .................. .4-5

Revised Final Site-Specific ERMP Pohakuloa Training Area, Hawaii

. iii April 2017

ASR bgs CD CFR CG Coe DGPS DoD DOE DU ELAP ERM ERMP HARNG HASL ICP-MS IM COM kg m2 msl mSv/y mrem/y NRC PAERMP

QA QC RCA RES RAD RSO SML SOP TA TEDE U-234 U-235 U-238 UFP-QAPP uxo


Archives Search Report Below Ground Surface Compact Disk Code of Federal Regulations Commanding General Chain-of-Custody Differential Global Positioning System U.S. Department of Defense U.S. Department of Energy Depleted Uranium Environmental Laboratory Accreditation Program Environmental Radiation Monitoring Environmental Radiation Monitoring Plan Hawaii Army National Guard Health and Safety Laboratory Inductively Coupled Plasma-Mass Spectroscopy Installation Management Command Kilogram Square Meters Mean Sea Level MilliSievert per Year Millirem per Year U.S. Nuclear Regulatory Commission Programmatic Approach for Preparation of Site-Specific Environmental Radiation Monitoring Plans Quality Assurance Quality Control Radiation Control Area Residual Radiation Radiation Safety Officer Source Material License Standard Operating Procedure Training Area Total Effective Dose Equivalent Uranium-234 Uranium-235 Uranium-238 Uniform Federal Policy for Quality Assurance Project Plans Unexploded Ordnance


lV April 2017

1.0 INTRODUCTION

This Site-Specific Environmental Radiation Monitoring Plan (ERMP) has been developed to fulfill the U.S. Army's compliance with license conditions #18 and #19 of the U.S. Nuclear Regulatory Commission (NRC) source material license (SML) SUC-1593 for the possession of depleted uranium (DU) spotting rounds and fragments as a result of previous use at sites located at U.S. Army installations. This Site-Specific ERMP is an annex to the Programmatic Approach for Preparation of Site-Specific ERMPs (PAERMP) (ML16004A369) (U.S. Army 2015) and describes the additional details related to Pohakuloa Training Area (TA) in Hawaii, in addition to those presented in the PAERMP.

1.1 PURPOSE

NRC issued SML SUC-1593 to the Commanding General (CG) of the U.S. Army Installation Management Command (IMCOM) authorizing the U.S. Army to possess DU related to historical training with the 1960s-era Davy Crockett weapons system at several installations nationwide. In order to comply with the conditions of the license, this Site-Specific ERMP has been developed to identify potential routes for DU transport and describe the monitoring approach to detect any off-installation migration of DU remaining from the use of the Davy Crockett weapons system at Pohakuloa TA. The installation will retain the final version of this Site-Specific ERMP. In accordance with license condition #19, the U.S. Army is required to implement fully this Site-Specific ERMP within 6 months of NRC approval. This Site-Specific ERMP and its implementation is then subject to NRC inspection. Table 1-1 summarizes the locations, media, and frequency of sampling described further in this Site-Specific ERMP.

Table 1-1. Recommended ERM Sample Location '

Sample Location I Sample Media I Sample Frequency

Co-located surface water and sediment samples downstream (ERM-01) from the RCAs, as

shown in Figure 1-2 based on the rationale presented in Section 2.1

Surface water and sediment based on the programmatic rationale presented in the P AERMP and

site-specific details presented in Section 2


Quarterly unless prevented by weather (e.g., regional flooding)

Pohakuloa TA is a 131,425-acre installation located on the island· of Hawaii, approximately 40 miles west of Hilo and 40 miles east ofKawaihae, Hawaii (Figure 1-1). A public highway, known as Saddle Road, traverses the northern portion of the area and serves as a major land route.

Pohakuloa TA was acquired by the United States from the State of Hawaii and private landowners. The facility is used by the U.S. Army Hawaii, the U.S. Marine Corps, and the Hawaii Army National Guard (HARNG).

Pohakuloa TA consists of a cantonment area, a maneuver area, an impact area, and a safety buffer zone. The cantonment area or Base Camp consists of administrative and logistical buildings, troop billets, Bradshaw Airfield, and the ammunition storage area. The Maneuver Area consists of limited road net and prominent terrain features. The Pohakuloa Impact Area is an area generally bounded on the north by Lava Road, on the east by Redleg Road, on the south by Kona-Hilo Trail, and on the west of Bobcat Trail.


1-1 April 2017

z

!

155*•0'0"W ,.......------------. Legend

L·- · 1 Pohakuloa Trail ing Area ·-' Installation Boundary

0 Radiation Control Area

0 Oudded Impact Area

[_] ICMArea

155.35'0'W

155.lO'O'W

r I/

I

155.30'0-W

NATIONWIDE DU PROGRAM (DAVY CROCKETI)

U.S.A

LOCATION MAP POHAKULOA TRAINING AREA

POHAKULOA, HI

DATE FIGURE

Q/612016 1-1


Revised Fi nal Site-Specific ERMP Pohakuloa Tra ining Area, Hawaii

1-2 April 20 17

Revised Final Site-Specific ERMP Pohakuloa Training Area. I lawaii

I \ I '

L-\ ---------

' / I

\ I

\ \

\ \, \,

\ \ ._...-,.;;::~ _ _,_-=..=~=-~ r

' \, :·

I ' ___________ j \,

'

Le0t:nd

A. Prq><>Sed ERM Sempllng Location"

+ SUrfac:e Waler F'°" D<edion

CJ R1clldon Ccntrot .a<e1

CJ Dudcled lrrc>ed /¥ea

D ICM Ar••

[_:-j Pohalculoo Trelning Ar.,. Installation Boondary ~ r ...... notul'tllOt~ Ilion OTdNJt~ o1......-ll'Otl'Wl1N~b0utdfl'y

.. , ,./

.,,.,.,....,.,

I

..:

/ I

/ /

/ I

~M-1 .. I

I I

I J

I

>·-

/

/ ""'

"" .............. --........

Figure 1-2. Radiation Control Area (Pohakuloa) and Proposed ERM Samples

1-3

IWJS'O"W

NATIONWtOEOU PROGRAM (DAVY CROCKETT)

U.S.A

RADIATION CONTROL AREA (POHAKULOA) & PROPOSED ERM SAMPLES POHAKULOA TRAINING AREA

POHAKULOA, HI

DAT£

"11/2017

FIGURI!:

1-2

April 20 17

'The Archives Search Report (ASR) (USA CE 2007) confirmed the presence of the Davy Crockett Range at Pohakuloa TA based on range type and use, historical range maps, and range regulations and common practice for the time period of the fielded Davy Crockett Weapon System (i.e., 1961 through 1968). The nearest normally occupied areas to the Davy· Crockett Ranges or radiation control areas (RCAs) are 16 miles west-northwest.

1.3 HISTORICAL INFORMATION

The MlOl spotting round contained approximately 6.7 ounces of DU, which was a component of the 1960s-era Davy Crockett weapons system. Used for targeting accuracy, the MlOl spotting rounds emitted white smoke upon impact. The rounds remained intact or mostly intact on or near the surface following impact and did not explode. Remnants of the tail assemblies may remain at each installation where the U.S. Army trained with the Davy Crockett weapons system from 1960 to 1968. These installations include Fort Benning, Fort Bragg, Fort Campbell, Fort Carson, Fort Gordon, Fort Hood, Fort Hunter Liggett, Fort Jackson, Fort Knox, Fort Polk, Fort Riley, Fort Sill, Fort Wainwright (includes Donnelly TA), Joint Base Lewis-McChord (Fort Lewis and Yakima TA), Joint Base McGuire-DixLakehurst (Frankford Arsenal Range), Schofield Barracks Military Reservation, and Pohakuloa TA.

The U.S. Army does not know if any cleanup or retrieval of these rounds or remnants has occurred at the Davy Crockett Ranges; therefore, it is assumed that most, if not all, of the 140 kilograms (kg) of DU from the rounds fired into RCAs at Schofield Barracks and Pohakuloa TA remains in the RC As.


Pohakuloa TA is in the Humuula Saddle between the two major peaks on the Island of Hawaii; Mauna Kea lies to the northeast and Mauna Loa lies to the south. Elevations within Pohakuloa TA range from 4,030 to 8,650 feet above mean sea level (msl).

Pohakuloa TA lies within the Northwest Mauna Loa and the West Mauna Kea watersheds, which drain to the northern Hualalai and southern Kohala coasts, respectively. There are no surface streams, lakes, or other bodies of water within the Pohakuloa TA boundary due to low rainfall, porous soils, and lava substrates. Rainfall, fog drip, and occasional frost are the main sources of water. Perennial streams are more than 15 miles from Pohakuloa TA on the northeast side of the island.

Rainfall is the primary source of groundwater recharge at Pohakuloa TA, and the geology is characterized by highly permeable lavas from which little or no runoff occurs. Most of the precipitation percolates relatively quickly to the underlying groundwater and then moves seaward, discharging into the coastal waters.

Pohaku1oa TA lies above two aquifer systems: the Northwest Mauna Loa and the West Mauna Kea aquifer sectors. The majority of Pohakuloa TA lies within the Northwest Mauna Loa aquifer sector. Based on regional hydrogeological information, it is believed that the groundwater beneath Pohakuloa TA occurs primarily as deep basal water within the older Pleistocene age basalts (U.S. Army 2013).


Source data were analyzed along with potential migration pathways and potential off-range human and/or ecological receptors. This information was collected for the RCAs and used to determine if a potential source-receptor interaction existed for each relevant pathway identified. Based on this analysis, the source-pathway-receptor interaction was considered unlikely for the Davy Crockett Ranges.


1-5 April 2017

No surface water or groundwater migration pathways were identified. Due to the low mobility of metals in soils and the depth to groundwater (greater than 1,000 feet below ground surface [bgs]), metals were not expected to infiltrate through the soil profile to groundwater. In addition, due to low rainfall, porous soils, and lava substrates, no perennial surface water bodies are located on, or immediately adjacent to, Pohakuloa TA. The closest known surface water body is located 4.5 miles upgradient of Pohakuloa TA. There are no perennial streams within 15 miles of Pohakuloa TA, but there are intermittent streams located northeast of Pohakuloa TA and only one intermittent stream, Popoo Gulch, drains the northern portion of Pohakuloa TA. Despite occasional flow, water in the intermittent stream channels infiltrates rapidly once precipitation stops and the streams become dry (EA 2013).


1-6 April 2017


The PAERMP documented the conditions (i.e., "if-then" statements) for the sampling of each environmental medium to be used during the development of the Site-Specific ERMPs, and only environmental media recommended for sampling in the P AERMP are presented in the sections below. Per the PAERMP, no sampling will occur within the RCAs or in the unexploded ordnance (UXO) areas (also referred to as Dudded Impact Areas). In addition, background/reference sampling is not required because the determination of DU presence will be based on an examination of the isotopic uranium ratios. The sampling approach and rationale for each medium for the Davy Crockett Ranges at Pohakuloa TA are discussed in the following sections.


There are no surface water features (i.e., streams, lakes, or other bodies of water) within the Pohakuloa TA boundary, and intermittent streams flow only following heavy rainfall and dry up quickly; therefore, sampling is restricted to sediment collection only. The sediment sampling approach will involve the collection of sediment samples from a location downstream from the RCAs in Pohakuloa TA (Figure 1-2). The sediment sampling location at Pohakuloa TA was selected based on the surface water hydrology and potential for DU contribution and is located as follows:

• ERM-01-The selected sampling point is located at an intermittent stream at the installation's northern boundary, downstream from the RCAs. ERM-01 is accessible using the Lightning Trail or via Saddle Road.

Sediment samples will be analyzed for total/isotopic uranium using U.S. Department of Energy (DOE) Health and Safety Laboratory (HASL) method 300 (alpha spectrometry). Further details of analytical procedures and quality assurance/quality control (QA/QC) information are presented in Annex 19. When analytical sampling results from locations outside the RCA indicate that the uranium-238 (U-238)/uranium-234 (U-234) activity ratio exceeds 3.0, the U.S. Army will notify NRC within 30 days and collect additional sediment samples within 30 days of the notification to NRC. The sediment samples displaying an activity ratio exceeding 3.0 will be reanalyzed using inductively coupled plasma-mass spectroscopy (ICP-MS) for their U-234, uranium-235 (U-235), and U-238 content to calculate the U-235 weight percentage specified in 10 Code of Federal Regulations (CPR) § 110.2 (Definitions) and then to determine if the sample results are indicative of totally natural uranium (at or about 0.711 weight percent U-235) or DU mixed with natural uranium (obviously less than 0.711 weight percent U-235).

2.2 GROUNDWATER

Presently, no groundwater monitoring wells are located at or near the RCAs. The depth to groundwater in the vicinity of Pohakuloa TA is approximately 1 ;ooo feet bgs. Although the area within the vicinity of Pohakuloa TA exhibits high soil permeability, the combination of limited precipitation and great depth to groundwater make it unlikely that DU would migrate into the groundwater. For these reasons and the additional rationale included in the PAERMP (U.S. Army 2015), groundwater sampling is not planned for Pohakuloa TA.

2.3 SOIL


routine operations and maintenance activities, the U.S. Army will sample that deposit semiannually with one sample taken per 25 m2 unless the soil erosion is located in a UXO area. The collection of ERM samples in UXO areas generally will not occur. Exceptions will occur only with documented consultation


2-1 April 2017

among the License Radiation Safety Officer (RSO), installation safety personnel, and range control personnel, who will advise the Installation Commander (i.e., they will prepare a formal risk assessment in accordance with U.S. Army [2014]). The Installation Commander will then decide whether to allow the collection. Otherwise, Pohakuloa TA does not meet any other criteria that would require soil sampling in accordance with the PAERMP (U.S. Army 2015).

Prior to mobilization, field sampling personnel will contact Range Control, the Installation RSO, or designee to determine if erosional areas within the RCA have been identified and, if so, sampled in accordance with requirements in Section 3.0 and Annex 19.


2-2

I

April 2017

3.0 ERMP ~ETHODOLOGY

The sampling and laboratory analysis procedures to be utilized during the ERM are described below. These procedures provide additional details and required elements to support the Site-Specific ERMP and must be utilized in conjunction with the standard operating procedures (SOPs) during execution of ERM activities. This Site-Specific ERMP is to be used in conjunction with Annex 19, which addresses programmatic requirements associated with ERM sampling, such as chain-of-custody (CoC), packaging for shipment, shipping, collecting field QC samples (e.g., field duplicate samples), and documenting potential variances from sampling procedures. Annex 19 has been prepared in accordance with guidance from the Uniform Federal Policy for Quality Assurance Project Plan (UFP-QAPP) Optimized Worksheets (IDQTF 2012). All entry to Pohakuloa TA will be coordinated with the Pohakuloa TA Installation Safety Office and Range Control prior to mobilizing for fieldwork.

\

Only a laboratory that the U.S. Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) has accredited for uranium analysis using both alpha spectrometry and ICP-MS methods will perform radiochemkal analyses for the purposes.ofNRC license compliance. The U-238 to U-234 activity ratio and the weight percent U-235 are used to determine whether a given sample is indicative of natural uranium or DU. The laboratory will use alpha spectrometry to analyze samples for U-234 and U-238 activities in order to comply with license condition #17 in NRC SML SUC-1593. All samples with U-238/U-234 activity ratios exceeding 3.0 will be reanalyzed using ICP-MS for their U-234, U-235, and U-238 content to identify samples with DU content (NRC 2016). The ICP-MS results for U-234, U-235, and U-238 are summed to calculate a total mass of uranium present, which will be used to calculate the weight percentage of U-235 and then to determine if the sample results are indicative of totally natural uranium (at or about 0.711 weight percent U-235) or DU mixed with natural uranium (obviously less than 0.711 weight percent U-235). Additional details about the sampling and analysis to support this Site-Specific ERMP are included in Annex 19.


No surface water samples will be collected because of the lack of surface water features (i.e., streams, lakes, or other bodies of water) due to low rainfall, porous soils, and lava substrates within Pohakuloa TA.

3.2 SEDIMENT SAMPLING

The collection of the sediment sample will consist of the compositing of at least 10 subsamples collected from various areas of the stream bed. Sediment samples will be collected from the stream bed using a clean, disposable plastic scoop. Sampling locations within the stream bed should be selected where the intermittent surface water flow is low and/or deposition is most likely. The sediment sampling procedure is as follows:

1. The individual performing the sampling will don clean gloves and prepare a disposable tray or sealable plastic bag and a plastic scoop.

2. Use a disposable scoop to remove the loose upper sediment uniformly from at least 10 subsample locations, starting downstream from the area to be sampled and moving upstream. Do not exceed 3 centimeters in depth into the sediment. Collect a sufficient quantity of sediment for QA/QC.

3. Place sediment into a disposable tray or sealable plastic bag (e.g., Ziploc®).



3-1 April 2017




8. Mark the sample location with a stake and log its coordinates using a differential global positioning system (DGPS) unit.


Additional details of the sediment sampling and the field procedures are provided in Annex 19. Once samples are collected, the samples and all QA/QC samples will be shipped to the selected laboratory for analysis. Sample handling (i.e., labeling, packaging, and shipping) and CoC procedures will follow those detailed in Annex 19.


3-2 April 2017


This section documents. the dose assessment results for a hypothetical residential farmer receptor located on each RCA, as applicable, and for the same receptor scenario located at the nearest normally occupied area, respectively. The dose assessments were completed to comply with license condition #19 ofNRC SML SUC-1593.

The dose assessments were conducted using the Residual Radiation (RESRAD) 7.2 (Yu et al. 2016a) and RESRAD-OFFSITE 3.2 (Yu et al. 2016b) default residential farmer scenario pathways and parameters with the following exceptions:

• Nuclide-specific soil concentrations for U-238, U-235, and U-234 were calculated for each RCA by multiplying the entire mass of DU listed on the license for the installation (140 kg for Schofield Barracks and Pohakuloa TA) by the nuclide-specific mass abundance, the nuclide specific activity, and appropriate conversion factors to obtain a total activity in picocuries (Table 4-1 ). That total activity was then assumed to be distributed homogenously in the top 6 inches (15 cm) of soil located within the area of the RCA.


Nuclide

U-234 6.22 x 10-3 3.56 x 10-4

U-235 2.16 x io-6 0.0938

U-238 3.36 x 10-7 99.9058

Depleted uranium• 3.6 x 10-7 100 a 10 CFR 20, Appendix B, Footnote 3. b Mass abundance calculations provided in Attachment 1.



• Groundwater flow was conservatively set in the direction of the off site dwelling.


4-1 April 2017

4.1 RESRAD INPUTS

Table 4-2. Non-Default RESRAD/RESRAD-OFFSITE Input Parameters for Pohakuloa Training Area RCAs

~~~AK3= for site contammants

Contaminated Zone

U-234 NIA Soil U-235 NIA concentrations (pCilg) U-238 NIA

Area of contaminated zone 10,000 (m2)

Depth of contaminated 2

zone (m)

Fraction of contamination 0

that is submerged

Length parallel to aquifer 100

flow (m)

Contaminated zone total 0.4

porosity

Contaminated zone hydraulic conductivity 10 (m/y)

Contaminated zone b 5.3

parameter

Average annual wind 2.0

speed (mis)

Precipitation rate (annual 1.0

rainfall) (mly)

Saturated Zone

Saturated zone total 0.4

porosity

Saturated zone effective 0.2

porosity

Saturated zone hydraulic 100

conductivity (m/y)

Saturated zone b 5.3

parameter

Unsaturated Zone

Unsaturated zone I, total . 0.4

porosity

Unsaturated zone I, 0.2

effective porosity

Unsaturated zone I, soil-5.3

specific b parameter

Unsaturated zone!, hydraulic conductivity 10 (mly)

' See Table 4-1.


1.38 x 10-2

1.26 x 10-3

0.21

1,000,000

0.15

0

1,000

0.43

4,930

4.38

5.3

0.51

0.43

0.33

4,930

4.38

0.43

0.33

4.38

4,930

" 1.38 x 10-2 L38 x 10-2 9.19 x 10-3 Site-specific calculation based on

1.26 x 10·3 1.26 x 10·3 8.41 x 10-4 the DU mass listed in the NRC SML (NRC 2016). =DU mass x nuclide specific mass abundance'

0.21 0.21 0.14 x nuclide specific activity' I (CZ area x CZ depth x CZ density)

1,000,000 1,000,000 1,500,000 Area of RCA

0.15 0.15 0.15 NRC SML SUC-1593, Item 11, Attachment 5

0 0 0 Depth to groundwater is approximately 1,000 ft bgs

1,000 1,000 1,500 Groundwater flows northeast across RCA

0.43 0.43 0.43 RESRAD Manual Table E.8 (DOE 200 I) for Fine Sand

RESRAD Manual Table E.2 4,930 4,930 4,930

(DOE 2001) for Loamy Sand

4.38 4.38 4.38 RESRAD Manual Table E.2 (DOE 2001) for Loamy Sand

5.3 5.3 5.3 U.S. Army 2013

0.51 0.51 0.51 U.S. Army 2013

0.43 0.43 0.43 RESRAD Manual Table E.8 (DOE 2001) for Fine Sand

0.33 0.33 0.33 RESRAD Manual Table E-8 (DOE 200 I) for Fine Sand

4,930 4,930 4,930 RESRAD Manual Table E.2 (DOE 2001) for Loamy Sand

4.38 4.38 4'.38 RESRAD Manual T!)ble E.2 (DOE 2001) for Loamy Sand

0.43 0.43 0.43 RESRAD Manual Table E.8 (DOE 2001) for Fine Sand

0.33 0.33 0.33 RESRAD Manual Table E-8 (DOE 2001) for Fine Sand

4.38 4.38 4.38 RESRAD Manual Table E.2 (DOE 200 I) for Loamy Sand

RESRAD Manual Table E.2 4,930 4,930 4,930

(DOE 200 I) for Loamy Sand

4-2 April 2017

Table 4-3. Non-Default RESRAD-OFFSITE Input Parameters Pohakuloa Training Area RCAs

RCA Layout Parameter I Area I I Area 2 I Area 3 I Area 4

Distance to nearest normally 4,900 3,400 4,400 6,000

occupied area (m)

Bearing of X axis (degrees) 135 (northeast) 135 (northeast) 135 (northeast) 135 (northeast)

X dimension of primary 1,000 1,000 1,000 1,000

-

contamination (m)

Y dimension of primary 1,000 1,000 1,000 1,500

contamination (m)

Location X Coordinate (m) Y Coordinate (m) X Coordinate (m) Y Coordinate (m) X Coordinate (m) Y Coordinate (m) X Coordinate (m) Y Coordinate (m)

Smaller Larger Smaller Larger Smaller Larger Smaller Larger Smaller Larger Smaller Larger Smaller Larger Smaller Larger

Fruit, grain, non-leafy 500 531.25

vegetables plot 6,000 6,032 500 531.25 4,500 4,532 500 531.25 5,500 5,532 500 531.25 7,600 7,632

Leafy vegetables plot 500 531.25 6,034 6,066 500 531.25 4,534 4,566 500 531.25 5,534 5,566 500 531.25 7,634 7,666

Pasture, silage growing area 500 600 6,216 6,316 500 600 4,716 4,816 500 600 5,716 5,816 500 600 7,816 7,916

Grain fields 500 600 6,066 6,166 500 600 4,566 4,666 500 600 5,566 5,666 500 600 7,666 7,766

Dwelling site 500 531.25 5,900 5,932 500 531.25 4,400 4,432 500 531.25 5,400 5,432 500 531.25 7,500 7,532

Surface-water body 500 800 6,316 6,616 500 800 4,816 5,116 500 800 5,816 6,116 500 800 7,916 8,216

;'.\tmospheric\l'ransport Pal'.ameter ( . "'~; ···, ,:;: ·~" . '.' '*·' "'l'' . ' :,·:;·· :· ' .;::·: '"• ·"'··· ,,s " ,, . ••••• '., ''"-.: !' . ·:t. .... '":

Meteorological ST AR file* CA_SAN_DIEGO.str CA_SAN_DIEGO.str CA_SAN_DIEGO.str CA_SAN_DIEGO.str

'b~ouri'clwate'i'Tra~sjliirt Param~ter ·· ·• ·: :'/: '•"' ~' ·' ,., ·-·: ,, .;, '0,· ' ·:/• '"'' "., .•. :·· .. ,, .. ,• ····'. '"'· '• · .. " ~ "

Distance to well (parallel to 4,900 3,400

4,400 6,000

aquifer flow) (m)

Distance to surface water 4,816 body (SWB) (parallel to 5,316 3,816 6,416 aquifer flow) (m)

Distance to well (perpendicular to aquifer 0 0 0 0 flow) (m)

Distance to right edge of SWB (perpendicular to -150 -150 -150 -150 aquifer flow) (m)

Distance to left edge of S WB (perpendicular to aquifer 150 150 150 150 flow) (m)

Anticlockwise angle from x axis to direction of aquifer 315 315 315 315 flow (degrees)

* ..

RESRAD Offs1te has no meteorological STAR files for Alaska or Hawan. The selected STAR file 1s based on nearest available location. The inhalation pathway dose 1s ms1gmficant to external and groundwater dose pathways.


4-3 April 2017

.. '

4.2 RESULTS

Table 4-4 presents the dose assessment results. Figure 4-1 presents graphs of the dose assessment results over the evaluation period. The calculated site-specific all pathway dose for each RCA evaluated at Pohakuloa TA does not exceed 1.0 x 10·2 milliSievert per year (mSv/y) (1.0 millirem per year [ mrem/y]) total effective dose equivalent (TEDE) and meets license condition # 19 of NRC SML SUC-1593.


RCA ~ Davy Crockett Range Area 1 0.025 0.012

Davy Crockett Range Area 2 0.025 0.013



a The onsite residential farmer receptor resides on the RCA. b The offsite residential farmer receptor resides off of the RCA, but within the installation, at the nearest normally occupied

area.



4-4 April 2017

Figure 4-1. Residential Farmer Receptor Dose Graphs for Pohakuloa Training Area RCAs

0.025

0.020 t

... 0.015 >. E: I!! E 0 .010

0.005

Davy Crockett Range Area 1

RCA Onsite (RESRAD)


. t ' ' ' I • c. I

- t +

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Years

-G-- U-23 4 ..+ U-2 3 5 -C- U-238 ~ Total

1000 10000

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0.012

0 .010 '

0 .008 '

>. E: 0 .006 . I!! E

0 .004 \

0 .002

0.000 0 20000 40000 60000

Years

80000

Revised Fina l Si te-Specifi c ERM P Pohakuloa Training Area, Hawaii

-G- U-23 4 ~ U-235 -C- U-2 38 -A- To ta l

PQ-JAKO..UAAREA 1.RCF 08129/20 16 14:52 Qaph ics .As c Incl udes All Path~

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April 20 17

0 .025

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~0 .015 1

e E 0 .01 o

0 .005 .


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. I , l , " , j, I j

'I I II ( I I [ 'i \[1

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...Q- U-234 ~ U-235 ....Q- U·238 -A- Total

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0 .014

0 .012 I

0 .010

f 0 .008 .

E E 0 .006 I

0 .004

0.002 '

0.000 0 20000 40000 60000

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-Q- U-234 -e- U-235 ~ U-238 -A- Total

P<l-V\KQUt\AREA2 .RCF 08/29/20 16 14 :53 Qap hi cs.Asc Includes Al l Pa th 'V

Revised Final Site-Specific ERMP Pohaku loa Training Area, Hawaii

4-6

100000 12000(

April 201 7

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0.020

i 0.015

E E 0.010 •

0.005


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1000

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0 .014

0 .012

0 .010

i 0 .008

E E 0 .006 ·

0 .004

0 .002

0 .000


DOSE: AllNuclides Summed , All Pathways Summed

10000

0 20000 40000 60000

Years

80000 100000 12000(

Revised Final Site-Specific RMP Pohaku loa Traini ng Area, Hawaii

-Q-. U-234 + U-235 _g_ U-23 8 ~ Total

PQlAKO..UAAREA3 .RCF 08129/20 16 14 :55 Qaphics .Asc Inclu des Al l Path1

4-7 April 201 7

...

0 .018

0.016 .

0.014 .

0 .012 '

~ 0 .010 '

I!! E 0 .008 ·

0 .006 '

0 .004 .

0 .002


RCA Onsite (RESRAD)

DOSE: AllNuclides Summed, All Pathways Summed

· 1 · 'I I 11·

' I

. +' I j !I

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1 10 100 1000 10000

Years

-G- U·234 ~ U·235 ...Q..- U·238 -A- Total

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8 .00E-0 3

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6 .00E-0 3 ·

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3 .00E-03 I

2 .00E-03

1.00E-03 ·

O.OOE+0 1 0

Revised Final Site-Spec ific ERMP Pohakuloa Train ing Area, Hawa ii


DOSE: All N uc lides Summed, All Pathways Summed

20000 40000 60000

Years

80000

-Q- U.234 + U-235 ....Q- U-238 ....,&.- Total

PGW<QU'\AREA4 .RCF 08129/2016 14 :57 Qaphics .Asc Includes AJI Path~

4-8

100000 12000(

April 201 7

Attachment 1



4-9 April 2017


Each of the values of the relative mass abundances for the naturally occurring uranium isotopes in the

legacy Davy Crockett depleted uranium on Army ranges helps determine the source terms for RESRAD

calculations, the performance of which is a license condition. This note shows how I estimated them

using the NRC default value for the specific activity of depleted uranium.

The third footnote to the tables in Appendix B ofTitle 10, Code of Federal Regulations (CFR), Part 20,

"Standards for Protection Against Radiation," says, "The specific activity for •.. mixtures of U-238, U-235,

and U-234, if not known, shall be: SA= 3.6E-7 curies/gram U for U-depleted." However, 10 CFR 20 does

not describe how the NRC arrived at that value and I have not been able to learn this from NRC sources.

In general, the following equation provides the speeific activity for a mixture of the three naturally

occurring isotopes of uranium1:

S= LS1 a1

i

Sis the specific activity of the mixture of naturaily occurring uranium isotopes, S, is the specific activity

for uranium isotope i,. a; .is the relative molar mass abundance for uranium isotope i in the depleted

uranium, and i denotes the uranium isotopes uranium-234 {134U), 235U and 238U.

Rather than looking up each S; in a table, I calculated them from fundamental values tci maximize

accuracy. By definition, the specific activity for a particular isotope S; is the activity A; per mass m1 for

the isotope i. Also, by definition:

A.1 is the decay constant and N, is the number of atoms of uranium isotope iin the sample with mass m;. Thus,

k is related to the half-life li<1 as follows:

ln2 A-=-

1 t'hi

If N, is set to Avogadro's .number (N = 6.02x1023),2 then, by definition, m1 is the mass of a mole of

isotope i, given by Iv[,, which is the atomic weight of isotope i with assigned units of grams. So,

'Although contaminants, including 236U, are possible, even likely, at levels less than parts per million, I am not including contaminants in these calculations nor in the RESRAD calculations because of their negligible impact on the results. 2 In performing the calculations, I used all available significant digits in a spreadsheet. This note generally displays only two or three significant digits in the equations. Minor discrepancies in calculated results are due to round-off.


4-10 April 2017

Analysis of NRC's Default Va Jue for Depleted Uranium Specific Activity

Values of the relative molar mass abundances, the half-lives, and the atomic weights for the naturally occurring uranium isotopes are available on a chart of the nuclides.3 The following table contains data used in calculations below:


Isotope Natural Relative Half-life Molar Mass Specific Activity"

Molar Mass Abundance (s) (g) (Bq g-1) (Ci g-1) 234u 0~000054 7.75x1012 234.04 2.30 x108 6.22X 10-3

235U 0.007204 2.22x1016 235.04 7.99 x104 2.16x10~ 238u 0.992742 1.41x1017 238.05 1.24x104 3.36x 10-7

By definition:

l = GU·234 + GU-235 + GU-238

A second equation involves the ratio of au.234 to au.min depleted uranium. If ao,u-234 is the natural relative mass abundance for 234U and ao,u.m similarly for 23sU, then

au-234 = ao.u-234Du-234

au-235 = CliJ.u-23sDu-2Js

Du.234 is the depletion of 234U in depleted uranium and Du.235 similarly for mu, with

0 (complete depletion) S D1 S 1 (no depletion)

Kolafa 5 estimated the depletion of 234U relative to the depletion of 235U as follows;

Du-234 = (1- 4E)" Du-23s = (1- 3E)"

e is the single stage enrichment efficiency per the difference of the uranium isotope atomic mass number from the atomic mass numberof238U and is much less than one. n is the number of enrichment stages.

For large n:

Du-234 """ e-4 ns

Du-235 """ e-3nc

Eliminate the product 11eby taking the logarithm of both equations:

In D0•234 = -4nE lnDu.235 ,;,, -3nE

3 For example, see http://atom.kaeri.re.kr/nuchart/. 4 1 curie (Ci)= 3.7 x 1010 becquerels (Bq) 5 http://www.ratical.org/radiation//V2aiic/u234.html

Page 2of 3


4-11 April 2017


So,

Substituting for ns

4 lnDu.234 = 3lnDu.z3s

Finally, exponentiating both sides of the equation,

So,

Thus,

- (4/3) Du.234 - Du.235

- (4/3) au.2H - Clo.u-n1Du-2Js

au-234 = (5.4· x 10-5)D~~m au.23~ = (7.204 x 10-3)Du.23s

au-23s = 1 - (5.4 x 10- 5)Dtl~{;~ - (7.204 x 10-3)Du.23s


s = 3.6 x 10-1 Ci g-1


(6.22 x 10-3 Ci g-1 )(s.1 x 10-5)Dtl:m + (2.16 x 10-6c1g-1)(1.201x10- 3)Du.235

+ (3.36 x 10-1 ci g-1 ) [ 1- cs.4 x 10-5)Dtl~m - c1.204 x 10-3)Du-2Js]

= 3.6 x 10-1 c1 g-1

Dividing by 10-7 Ci g·1 and collecting terms,

Solving, Du--m = 0.13, and6

3.36Dtl:{;~ + 0.131Du-2Js - 0.239 = 0

au.n• = 0.00000356 au-:m = 0.00093806 au.ZJs = 0.99905838

6 The values for 13•u and mu actually contain only one or two significant digits. I show more digits because I will use them in RESllAD calculations. Properly, the results should read au.234 = 0.000004, au•m = 0.0009, and . au.238 = 0.9991. For comparison, typical isotopic abundances in depleted uranium according to the Department of Energy are au.m = 0.000007, au.2Jl = 0.0020, and au.2Js = 0.9980 (DOE-STD-1136-2009), which corresponds to a specific activity of S = 3.8 x I 0-7 Ci g·1• I note that the derived DOE value for Du.:m is 0.13, which is inconsistent

with Kolafa's estimate calculated from the derived DOE value for Du.13i: D~~fti = (0.28)«113l = 0.18.


Page3 of 3

4-12 April 2017

5.0 REFERENCES


EA (Engineering, Science, and Technology, Inc.). 2013. Final Operational Range Assessment Program, Phase I Qualitative Assessment Report Addendum, Pohakuloa Training Area, Hawaii, Hawaii. December.

IDQTF (Intergovernmental Data Quality Task Force). 2012. Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) Manual, Optimized UFP-QAPP Worksheets. March.


U.S. Army. 2013. Final Environmental Impact Statement for the Construction and Operation of an Infantry Platoon Battle Course at Pohakuloa Training Area, Hawaii. Prepared for U.S. Army Pacific and U.S. Army Garrison Hawaii. Prepared by U.S. Army Environmental Command with assistance from Applied Sciences & Information Systems (AScIS), Inc. and Booz Allen Hamilton. Available at (https ://www.garrison.hawaii.aimy.mil/pta peis/ documents.htm ).


U.S. Army. 2015. Programmatic Approach for Preparation of Site-Specific Environmental Radiation Plans (NRC ADAMS accession number ML16004A369).

USACE (U.S. Army Corps of Engineers). 2007. Final Archive Search Report on the Use of Cartridge, 20MM Spotting MlOl For Davy Crockett Light Weapon M28, Schofield Barracks and Associated Training Areas, Islands of Oahu and Hawaii. U.S. Army Corps of Engineers, St. Louis District. May.


Yu, C. et al. 2016b. RESRAD-OFFSITE (Version 3.2) [Computer Program]. Available at http://web.ead.anl.gov/resrad/RESRAD Family/ (Accessed July 14, 2016). June.

Revised Final Site-Specific ERMP f ohakuloa Training Area, Hawaii

5-1 April 2017

reply to attention of · res rad rso slua sml sop ta tede u-234 u-235 u-238 ufp-qapp uxo wwii ......

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